Case No. IA-2015-321890-1

Date issued: Apr. 12 2016

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TURBOFAC Commentary (630 words)

Notes:

1) Fish Specimen as “Iranian-origin Goods”.

OFAC cites 560.518(a) of the ITSR as the authority for the proposed activities, and 560.518(a) applies to dealings in “Iranian-origin goods located in the United States” that would otherwise be prohibited by 560.206. 560.306 provides that “terms goods of Iranian origin and Iranian-origin goods include: Goods grown, produced, manufactured, extracted, or processed in Iran.”

The letter implies that a fish specimen would fall within the scope of the term “goods” for the purposes of 560.306. This is not necessarily obvious. Compare e.g. [WMDPSR / ITSR] - General License No. 2 (Iranian vessels are apparently not “goods”) and Case No. IA-2014-314878 (rock samples are “Iranian origin goods”). It is not specified in the letter, but the fish specimens here...