031125-FACRL-IA-12. Iran: Travel Exemption

Date issued: Nov. 25 2003

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TURBOFAC Commentary (435 words)

Notes:

1) The Guidance analyzes a set of transactions at the intersection of the Berman Amendment exemptions for travel and transactions ordinarily incident thereto (560.210(d)) and the exemption for informational materials transactions (560.210(c)).

With regard to OFAC's declaration that "the Regulations do not prohibit [the advertisement of air service between the United States and Iran] unless they are undertaken at the behest of a person in Iran or an Iranian entity," compare FAC No. CU-156123, considering a Cuban travel company paying a U.S. person to broadcast advertising as being within the scope of informational materials exemption (i.e. where the travel exemption was not available). The reason why the advertising generally is not permitted is because OFAC deems it i) not ordinarily incident to travel, and ii) more of a service than a transaction incident to the import/export of informational materials, but...