Case No. IA-2018-358410-1

Date issued: Jul. 08 2019

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TURBOFAC Commentary (1240 words)

Notes:

1) BACKGROUND

The applicant university requests guidance on the question of whether it may “ship I-20 or DS-2019 visa documentation to Iranian graduate and undergraduate students.” There are a few discrete Berman Amendment-related questions embedded within the request.

One is whether the “I-20 or DS-2019 visa documentation” qualifies as “informational materials” for the purposes of the exemption at 560.210(c) of the ITSR. The other is whether—assuming that the documentation is “informational materials”—the university may ship the documents to Iran.

2) SHIPMENTS AND SHIPPING OF EXEMPT INFORMATIONAL MATERIALS IS, ITSELF, EXEMPT

We understand, based on the titling of the guidance letter as received by us, that the guidance letter was obtained by the university in part to provide comfort to the shipper DHL that the shipment...