Case IA-8039 - [Application Included in Original PDF]

Date issued: Aug. 01 2006

Last substantive commentary amendment:
Jan. 02 2024

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TURBOFAC Commentary (924 words)

Notes:


* For commentary on this guidance letter in the context of other Research System letters dealing with this topic, see General Note on U.S. Organizations Providing Membership and Related Benefits to Sanctioned Persons (System Ed. Note).


1) Compare with Case IA-6489, with respect to with the request for guidance here sought clarification. This guidance makes the same point about a third party funding the travel of an Iranian being exempt under 560.210(d), except here OFAC confirms that 560.210(d) applies i) even to an Iranian traveling to a country other than the U.S., ii) where the funds transferred are reimbursements for travel-related costs that are not necessarily transportation such as travel and food (described in the letter as "reasonable out of pocket expenses"). 


2) In Case No. IA-6489, OFAC determines that so long as "the goods are of a type and in quantities nominally given as gifts...