Mastercard Incorporated, 2016; 2018; 2019 10-K Filings, 2020 Q3 10-Q

Date issued: Oct. 28 2020

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (1313 words)

Notes:

*[Note – on September 10, 2024, Iran Air was designated by OFAC and State pursuant to two different sanctions authorities (https://home.treasury.gov/news/press-releases/jy2570), and “Concurrent with [the] action, international partners are announcing measures which will not allow Iran Air to operate in their territory in the future and are pursuing further designations of Iran- and Russia-based individuals, entities, and vessels involved in the transfer of Iranian lethal aid to Russia.” It is unclear whether this means that the USG would take a different secondary sanctions approach to Iran Air than it has in the past as it relates to civil aviation-related transactions (e.g. refueling in third countries)].

1) ALLOWING AN IRAN AIR/GOI-LINKED ENTITY TO BE A MASTERCARD MERCHANT

Mastercard interprets the Berman Amendment exemption of the ITSR for transactions ordinarily...