Case No. IA-2014-314878
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University Export Compliance Officer and Export Compliance Counsel
Office of Sponsored Projects
The University of Texas at Austin
101 E. 27th Street, Suite 5.300
Mail Stop, A9000
Austin, TX 78712-1532
Dear Mr. Ivey:
This is in response to your request dated December 11, 2014 (the “Application”) on behalf of the University of Texas at Austin to the Office of Foreign Assets Control (OFAC). Specifically, you are requesting interpretive guidance as to whether authorization is necessary in order for you to analyze rock samples of Iranian origin that were originally obtained and imported into the United States pursuant to the authorization of OFAC License No. IA-5679 and to publish the results of the findings.
The Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. Part 560,...
1) “Domestic Transactions”
The applicant university asks whether a license is required in order to “analyze rock samples of Iranian origin that were originally obtained and imported into the United States pursuant to [a specific license,] and to publish the results of the findings.”
The answer provided has implications for a few provisions of the ITSR. 560.518(a) of the ITSR is a broad authorization for “[a]ll domestic transactions with respect to Iranian-origin goods located in the United States other than goods blocked pursuant to §560.211.” The term “domestic transaction” is not defined in the ITSR, and we are not aware of any guidance that speaks to the question of whether a “domestic transaction” is one that has no international character or implications whatsoever, or merely one that is carried out principally...