Case No. IA-2013-300350-1

Date issued: Jul. 08 2013

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TURBOFAC Commentary (714 words)

Notes:

1) Read in conjunction with Case No. IA-2019-364065-1, where the analysis below applies, but to all types of persons on visas described in 560.505 (not just students).

OFAC considers the students in the U.S. to be "ordinarily resident" in Iran such that, without some other source of information, any services provided to them in the form of opening and maintaining accounts would constitute exports of services "to Iran" (560.204/560.410).

2) Here, OFAC finds the source of authority for the opening and operation of the bank accounts for students to be the combination of 560.505(a) and 560.405. The notion that opening a bank account for a person would be a transaction deemed to be within the scope of the "ordinarily incident" interpretive provision appears novel, at least on the basis of the guidance available to...