ENF 46381 ("License Determination")

Date issued: Aug. 08 2016

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TURBOFAC Commentary (429 words)

Notes:

1) This is one of several “License Determination” or “Regulatory Question” documents prepared by OFAC enforcement, usually within a matter of days after being request, at the request of another U.S. government agency (BIS/DOJ) in connection with a sanctions related investigation. While it is unclear what the status of these documents are authoritative positions of OFAC for purposes of the APA, they are nevertheless notable where they address novel questions.

2) Here, the context is a criminal prosecution involving an Iranian individual (Matteo Taerri) based in Florida who exported of biological vectors and medical filters classified under ECCN 2B352 to Iran. According to BIS, “Taerri was providing the biological material and filters to his nephew, who was a PhD student at Tehran University Research Center and claimed to...