Case No. IA-15582, License No. IA-15582

Date issued: May. 18 2011

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TURBOFAC Commentary (306 words)

Notes:

1) See pp. 52-56 of native PDF file. As discussed in the comments to Case No. IA-15877, there are several guidance letters that contain statements similar to the ones found in the last substantive paragraph of this license. This is the only one that specifies that a U.S. person holder of a pre-existing investment in an Iranian company must be a "non-majority" shareholder for there to be any chance of a continued investment not coming within the scope of any of the ITSR’s prohibitions.

Civil Enforcement Information - Clearstream Banking, S.A. and some other enforcement actions construe "custodial services" (i.e. the holding of securities for the indirect benefit of a person in Iran) as a "service" within the scope of the ITSR. Query: does the possibility...