General Note on the Immigration-related GLs in the ITSR and SySR, and Dealings With Sanctioned Iranian and Syrian Individuals Lawfully Present in the U.S. (System Ed. Note)

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 (5284 words)

General Note on the Immigration-related GLs in the ITSR and SySR, and Dealings With Sanctioned Iranian and Syrian Individuals Lawfully Present in the U.S. (System Ed. Note)

1) INTRODUCTION, RELATIONSHIP BETWEEN ITSR AND SYSR VERSIONS

560.505 of the ITSR and 542.521 of the SySR are the primary GLs that authorize transactions related to the legal presence of sanctioned Iranians and Syrians in the United States. The two GLs are virtually identical in scope The primary substantive differences are (i) that 560.505 has a section addressing “deemed exports” to students that is not necessary for the SySR due to the fact that the SySR has no broad prohibitions covering exports of items subject to the EAR, and (ii)...