LICENSE No. IA 18173

Date issued: Mar. 26 2012

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TURBOFAC Commentary (134 words)

Notes:

1) See related OFAC/USG amicus brief at Ministry of Def. & Support for the Armed Forces of the Islamic Republic of Iran. MODAFL prevailed in an international arbitration against the U.S. person Cubic Defense Systems, and the USG took the position that confirmation (but not enforcement) of the award by a federal court was authorized by 544.507 of the WMDPSR and 560.525(a)(5)(i) of the ITSR.

From a licensing policy perspective, it is notable, though probably not too surprising, that OFAC required payment to MODAFL to be made into a blocked account (which may have subjected it to attachment by judgment creditors of the Iranian government). Were the situation reversed,...