BIS Advisory Opinion - Reexports to Iran

Date issued: Jul. 14 2003

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TURBOFAC Commentary (102 words)

Notes:

1) Compare this advisory opinion with Case No. IA-11787. 746.7(a)(3) of the EAR says that BIS will not issue licenses where OFAC has already done so, and in this letter BIS suggests that OFAC is "the licensing agency" for Iran. However, in Case No. IA-11787, OFAC appears to take the position that 560.505 will cover deemed exports to the extent that such exports have been licensed by BIS. In such cases, and presumably in others as well, one would need to approach BIS for a license in order to trigger a pre-existing general license contained in the ITSR.