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Case No. IA-2016-329380-1
Rebecca Merritt
Registrar
Smithsonian Institution/Freer Gallery of Art and Arthur M. Sackler Gallery
P.O. Box 37012, MRC 707
Washington, DC 20013
Dear Ms. Merritt:
This responds to your letter dated April 27, 2015 (the "Application"), to the Office of Foreign Assets Control (OFAC), seeking authorization to import into the United States an Iranian-origin portrait of Jalal al-Din Mirza, painted in 1859.
The Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR), generally prohibit the importation into the United States of any goods or services of Iranian origin or owned or controlled by the Government of Iran. ITSR, § 560.201. Additionally, the ITSR generally prohibit U.S. persons, wherever located, from engaging in any transaction or dealing in or related to goods or services of Iranian origin or owned or...
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1) Case No. IA-2015-318952-1 and Case No. IA-2016-329380-1 are two letters that address Smithsonian importation-related guidance/license requests that were made by Smithsonian on the same day (via a “letter dated April 27, 2015”). While Case No. IA-2015-318952-1 was issued on 08/12/2015, this response was issued on 07/13/2016, over a year after the making of the guidance request. We only have the application associated with Case No. IA-2016-329380-1.
The details concerning the item at issue here—the Iranian-origin portrait of Jalal al-Din Mirza, painted in 1859—can be found at https://collections.si.edu/search/detail/edanmdm:fsg_S2016.9a-b. (Accession in 2016, purchased by the "Friends of the Freer and Sackler Galleries," i.e. the "distinguished patrons group" of the Freer and Sackler Galleries). This is clearly an “artwork” that would be “classified under chapter heading 9701, 9702, or 9703 of the Harmonized Tariff Schedule of the United...