Published Transcript; OFAC-BIS "Webinar – Sanctions Update Cuba/Iran/Russia"

Date issued: Mar. 30 2016

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TURBOFAC Commentary (1196 words)

Notes:

* On 9-23-22, OFAC replaced Iran GL D-1 with Iran GL D-2. See Iran GL D-2, and comments thereto, for a discussion on the changes between GL D-1 and GL D-2. The comment below has not been amended as a result of the issuance of GL D-2, but the substance of the comment would not change as a result of the changes between D-1 and D-2.

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1) Rare, on-the-record presentation involving OFAC. Some of the more difficult, common questions posed by participants in the webinar are avoided (e.g. concerning the "general inventory rule" and the scope of "facilitation), but the representatives from OFAC do go on record with some notable guidance that is not otherwise apparent from the regulation or other on-the-record, public statements made by the agency.

2) IN RE: 560.505 & 560.418 [Exports of Technology to Iran through...