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Case No. IA-2015-318609-1
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This is in reply to your request dated April 22, 2015, (the "Application") to the Office of Foreign Assets Control (OFAC) seeking a license authorizing [redacted U.S. person] to enter into an agreement with [redacted Iranian entity] in Iran to serve as [redacted U.S. person’s] exclusive agent in Iran, providing services to translate, add subtitles to, market, and pay royalties for professional training videos for mental health professionals in Iran.
The Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR), generally prohibit the exportation, reexportation, sale, or supply directly or indirectly , from the United States or by a U.S. person, wherever located, of any goods, technology or services to Iran or the Government of Iran. ITSR, § 560.204. Additionally , the ITSR generally prohibit U.S. persons, wherever located, from engaging...
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1) Confirmation that Translation of Exempt Informational Materials is, Itself, Exempt
Read in conjunction with 030203-FACRL-IA-01. Case No. IA-2015-318609-1 serves as evidence that 030203-FACRL-IA-01 was removed from OFAC's website as a result of a of a change in licensing policy, rather than as a change in OFAC's interpretation of the scope of the Berman Amendment as it relates to translation. 030203-FACRL-IA-01 says that:
“[t]he participation by a U.S. person in a transaction involving the dubbing or subtitling of films in Iran or at the direction of an Iranian entity is covered by the exemption since such activities are incidental to the distribution of the films in a country in which the language is not that in which the films were made, provided that the dubbing and subtitling entail no substantive or artistic alterations or enhancements.”
This guidance...