Case No. IA-11335

Date issued: Jan. 13 2009

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TURBOFAC Commentary (708 words)

Notes:

1) At the time this guidance was issued 560.508 provided that:

"All transactions of common carriers incident to the receipt or transmission of telecommunications and mail between the United States and Iran are authorized. For purposes of this section, the term mail includes parcels only to the extent the parcels contain goods exempted from the prohibitions contained in this part or otherwise eligible for importation from or exportation to Iran under a general or specific license."

Since the issuance of this guidance, OFAC amended 560.508 to distinguish between telecommunications and mail, where "mail is limited to personal communications not involving a transfer of anything of value," but with respect to "telecommunications," which in the case of a company like Sprint would presumably include data and voice calling, OFAC imposes no such requirement.

2) Post Bank of Iran was designated as an...