Case No. IA-16194

Date issued: Jun. 12 2012

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TURBOFAC Commentary (780 words)

Notes:

1) Guidance confirms that OFAC does not consider the Berman Amendment IEEPA exemptions (i.e. travel, informational materials) to apply to entities designated under the GTSR, but acknowledges they do apply to entities designated under the WMDPSR (such as Iran Air, which was an NPWMD at the time of the guidance but is not as of 7/2021). See FAQ 534, and comments thereto, on the legal basis for the application of the Berman exemptions to Iran Air, but not Mahan Air.

2) "Interline and special prorate agreements with Iranian airlines" are deemed ordinarily incident to travel, but see