OFAC Third Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry (August 7, 2015)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (255 words)

Notes:

1) This does not appear on OFAC's main Iran sanctions page, but as of 5/2019, it has not been formally revoked following the U.S. withdrawal from the even though it was issued in connection with the in 2015.

2) Now that Iran Air is, as of 5/2019, no longer designated pursuant to the , this SLP appears to be of little use beyond the one located at 560.528. The apparent purpose of the SLP was to ensure that Iran Air could benefit from 560.528. In 2015, Iran Air was an , and the WMDPSR had/have no aircraft safety SLP, meaning that 560.528 did not apply to Iran Air.

3) Read in conjunction with, and see comments to, 030509-FACRL-IA-06, Exports/Aircraft Safety- (Guidance Currently on OFAC's website), discussing the relationship between this SLP, 560.528, and the Iran-Iraq Arms Nonproliferation Act. There is reason to believe that 030509-FACRL-IA-06 suggests a more restrictive licensing policy with respect to airline safety-related items than is currently in place, but this is unclear.

4) Read a contrario; the following activities are, impliedly, generally outside the scope of the travel exemption located in the and WMDPSR:

"the exportation and reexportation of: services related to the inspection of commercial aircraft and parts in Iran or a third country; services related to the repair or servicing of commercial aircraft in Iran or a third country; and goods or technology, including spare parts, to Iran or a third country."

Welcome!

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Third Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry (August 7, 2015)

TURBOFAC Commentary (255 words)