CROSS Customs Ruling NY I82142

Date issued: Jun. 10 2002

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TURBOFAC Commentary (640 words)

Notes:

1) Customs ruling illustrating the extraordinary breadth of 560.206 of the ITSR, but with what appears to be a notable accommodation on the part of OFAC having the effect of tempering the breadth of the provision.

2) 560.206, on its face, prohibits "any transaction or dealing in or related to…[g]oods…of Iranian origin…" The 1997 EO that this provision implements probably did not expect that provision to cover, for 23 years and counting, 100-year-old antiques originating in what was at the time called the "Sublime State of Persia," part of which was located outside of the territory of modern Iran, and located in a country other than Iran since before the current embargo was imposed.

Here, customs reports that "OFAC has waived any license...