Iran General License (No. H) - Authorizing Certain Transactions relating to Foreign Entities Owned or Controlled by a United States Person [Revoked]

Date issued: Jan. 16 2016

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TURBOFAC Commentary (246 words)

Notes:

1) Iran General License (No. H) was revoked pursuant to the withdrawal of the U.S. from the JCPOA, but the license and the FAQs interpreting the license remain extremely valuable for their statements, both express and implied, concerning the scope of the basic facilitation prohibition (560.208, as interpreted by 560.417). GL H authorizes certain activities by U.S. persons in connection with entities subject to the ITSR as a result of 560.215 that, but for the license, would constitute the prohibited “facilitation” of such activities.

These statements have presumptive cross-programmatic relevance, further fleshing out OFAC's detailed descriptions of what constitutes prohibited facilitation in the now-repealed Sudanese Sanctions Regulations (see § 538.407 - Facilitation by a United States person...