Civil Enforcement Information - ATP Tour, Inc.

Date issued: Jun. 12 2013

TURBOFAC Commentary (133 words)

Notes:

1) It is notable that OFAC does not characterize the violations as an export of financial services "to Iran" as a result of the referee being ordinarily resident in Iran.

Instead, OFAC seems to consider the payments to violate 560.206 and 560.208 because they were facilitative or and "related to" "Iranian origin" services, i.e. those of the referee that was ordinarily resident in Iran. These services are of "Iranian origin" even if performed in a third country, as was probably the case here.

560.306 specifies that "Services performed outside Iran by a citizen, national or permanent resident of Iran who is ordinarily resident in Iran, or by an entity organized under the laws of Iran."

2) This activity would not be authorized by Iran General License (No. F).