Case No. MUL-2013-305202-1

Date issued: Mar. 07 2016

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TURBOFAC Commentary (238 words)

Notes:

1) Note the amount of time it took for OFAC to respond to the applicant, generally indicating a need for interagency review and/or the guidance being precedential in some fashion. In this case, OFAC addresses questions concerning "certain transactions involving the collection of old coins from Cuba and Iran." But way the response is phrased, in terms of "Coin Currency of Sanctioned Countries," appears to mean that the guidance is not limited to “old” currency.

2) Two central, threshold questions here are whether “Coin Currency of Sanctioned Countries” constitute “merchandise” for the purposes of the CACR and “goods” for the purposes of the ITSR. Note that ‘funds’ in general are not goods or merchandise. For example, if a U.S. bank receives a wire from an Iranian bank,...