31 CFR § 560.516 Payment and United States dollar clearing transactions involving Iran (2006, Iran)

Date issued: Nov. 30 2006

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TURBOFAC Commentary (797 words)

Notes:

1) THE UNANNOUNCED CHANGE IN THE SCOPE OF THE NOTION OF AN EXPORT OF "SERVICES" TO A SANCTIONED COUNTRY

This is the section of the ITR (now ITSR) that contained what is referred to as the "U-turn" general license. The section, which was substantially modified in 2012 when the ITR were reissued as the ITSR, is notable in part for support for the proposition that the scope of the term "service" has been something of a moving target over the past decade or so.

The provision authorizes United States depository institutions to process transfers of funds to or from Iran if:

"[t]he transfer arises from an underlying transaction that is not prohibited by this part, such as a non-commercial remittance to...