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Case No. IA-2021-870300-1
Jim Mullinax, Director
U.S. Department of State
Bureau of Economic and Business Affairs
Office of Sanctions Policy and Implementation
2201 C St., NW
Washington, DC 20520
Dear Mr. Mullinax:
This responds to your request to the Office Of Foreign Assets Control (OFAC) dated September 17, 2021 (the "Application"), seeking a specific license to the extent authorization is required under the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR) for transactions by the U.S. Department of State, the United States Agency for International Development, and their employees, contractors, and grantees (the "Licensees"), related to the purchase in Lebanon of Iranian-origin petroleum products. As described in the Application, you do not anticipate that the Licensees will purchase petroleum products that they know to be of Iranian origin or that they...
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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...