Case No. IA-2021-870300-1

Date issued: Sep. 17 2021

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TURBOFAC Commentary (675 words)

Notes:

1) Read in conjunction with Case No. IA-2021-870300-1, and comments thereto. In taht letter, OFAC says that U.S. person (more specifically the Defense Logistics Agency) can purchase “refined fuel products” from non-U.S. oil refineries that have produced the fuel through the “substantial transformation” or Iranian-origin crude oil. That letter cites 560.407(a) of the ITSR, which provides that “[i]mportation into the United States from third countries of goods containing Iranian-origin raw materials or components and transactions relating to such goods are not prohibited by §560.201 or §560.206 if those raw materials or components have been incorporated into manufactured products or substantially transformed in a third country by a person other than a United States person…”

On its face, 560.407 of the ITSR addresses “[i]mportation into the United States...