Case No. IA-2015-323596-1

Date issued: Jul. 26 2016

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TURBOFAC Commentary (524 words)

Notes:

1) The applicant asks whether the provision of a service to a person that has worked for a blocked person is prohibited under the ITSR. In particular, the question is whether a U.S. person may accept a student into a master’s program. OFAC does not address the source of authority for the provision of services in connection with the acceptance of a student resident in Iran. This would appear to be Iran General License (No. G), rather than 560.505.

2) The identity of the specific blocked entity at issue is redacted, but the context of the letter makes it fairly certain that the entity would meet the definition of “Government of Iran”. The only blocking regulation cited in the letter is 560.211 of the ITSR, the...