Case No. IA-2015-318609-1

Date issued: Sep. 19 2016

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TURBOFAC Commentary (785 words)

Notes:

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...