Iran General License (No. J-1) - Authorizing the Reexportation of Certain Civil Aircraft to Iran on Temporary Sojourn and Related Transactions (Amended 12/15/2016)

Date issued: Dec. 16 2016

Last substantive commentary amendment:
Jun. 12 2023

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TURBOFAC Commentary (1540 words)

Notes:

1) While this license was issued in connection with the JCPOA, it was not revoked subsequent to the U.S. withdrawal from the agreement. As discussed below, this has led to a quirky result with respect to entities subject to the ITSR solely as a result of 560.215, which appear to be covered by this GL with regard to CCL-listed planes, but not planes that are not subject to the EAR altogether.

2) As noted in the comments to JCPOA Implementation FAQ K-13, where OFAC also makes reference to the term "controlled content" in the re-export context, that term is unique to the EAR. It appears in no regulation...