Case No. IA-11787

Date issued: Mar. 08 2013

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TURBOFAC Commentary (1527 words)

Consolidated Comment on Case No. IA-10466 and Case No. IA-11787

1) BACKGROUND

Case No. IA-10466 and Case No. IA-11787 (both in native PDF file) are virtually identical guidance letters issued to the same company four and a half years apart. The primary distinctions between the two letters are (i) that the first one address the ITR, while the second one addressed the reissued ITSR, (ii) the second letter redacts the name of the Iranian national employee, who is likely different from the person at issue in the first letter (this explains why in the second letter OFAC says “Please be guided by the following in this and future similar circumstances”), and (iii) in the first letter OFAC notes refers to an “Iranian national...