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Case No. MUL-2013-305202-1

Date issued: Mar. 07 2016

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Case No. MUL-2013-305202-1

[ ]
DBA Numisphere
P.O. Box 312
Stormville, NY 12582

Dear [ ]:

This responds to your request dated September 30, 2013 (the “Application”), on behalf of DBA Numisphere (“Numisphere”), to the Office of Foreign Assets Control (OFAC), in which you request information regarding the applicability of OFAC-administered sanctions to certain transactions involving the collection of old coins from Cuba and Iran (“Coin Currency of Sanctioned Countries”). According to your Application, Numisphere acquires Coin Currency of Sanctioned Countries by purchasing them from other collectors in the United States, from other U.S. coin dealers, or at public auctions either in the United States or the international market. Also, according to your Application, you do not acquire Coin Currency of Sanctioned Countries directly from embargoed countries or from nationals of those countries either in the United...

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TURBOFAC Commentary (244 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,...