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OFFICE OF FOREIGN ASSETS CONTROL
LICENSE DETERMINATION
ENF 46381
August 8, 2016
Date of Request: August 8, 2016
Requestor's Name: Ariel Joshua Leinwand
Originating Agency: BIS, OEE, Atlanta, GA
Unless otherwise authorized, the exportation, reexportation, sale or supply, directly or indirectly from the United States, or by a U.S. person of any goods, technology or services to Iran or the Government of Iran is prohibited pursuant to the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (the "Regulations"), issued under the authority of the International Emergency Economic Powers Act, 50 U.S.C. §§ 1701-06 (IEEPA), and other statutes.
Section 560.524(a) of the Regulations authorizes the exportation from the United States to Iran of household and personal effects, including baggage and articles for family use of persons departing the United States to relocate...
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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...