Case No. IA-2014-314878

Date issued: Apr. 20 2015

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TURBOFAC Commentary (474 words)


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...