Case No. IA-2013-304156-1

Date issued: Jun. 14 2014

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TURBOFAC Commentary (183 words)

Notes:

The applicant university asks whether a license is required to ship a DVD that provides “provides step-by-step directions of how to conduct the Balance Evaluations Systems Test (BESTest) on a patient.” [1]. The definition of “Information or informational materials” explicitly includes “compact disks [and] CD ROMs,” and in this case it seems fairly clear that the materials were not created at the behest of any Iranian person, so the applicant is presumably inquiring as to whether the actual shipping of the exempt informational materials is, itself, exempt. The answer is yes (compare Case No. IA-2018-358410-1). Consistent with OFAC’s typical practice in these cases, the agency avoids making a clear statement that transactions incident to exempt transactions are themselves exempt, but this is agency practice. Compare also Exempt transactions (1999, Cuba); FR Notice Implementing 1989 Version of the Berman Amendment in...