PRINT
Case No. IA-7041
PETER D. TROOBOFF, Esquire,
Covington & Burling,
1201 Pennsylvania Avenue, N.W.,
Washington, DC. 20004-2401
DEAR MR. TROOBOFF:
This responds to your letters of December 21, 2004, and January 10, 2005, on behalf of Exxon Mobil Kazakhstan Inc. and its affiliates (collectively, "ExxonMobil"), requesting confirmation that certain transactions by ExxonMobil in connection with its participation in current and proposed activities relating to the North Caspian Production Sharing Agreement are not prohibited by the Iranian. Transactions Regulations, 31 C.F.R. Part 560 (the "ITR"). You explain that in November 1997, the Government of Kazakhstan entered into a Production Sharing Agreement ("PSA") with a consortium of international petroleum companies (the "Consortium"), which entitles Consortium members to explore for oil, develop discovered reserves, and produce oil from several blocks in the northern Caspian Sea. Agip KCO, a...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
1) Interpretive guidance concerning a version of the ITR (now ITSR) that existed prior to the blocking of the GOI, and prior to the application of the ITSR to non-U.S. entities owned or controlled by U.S. persons. The version in force at the time did, however, have the same basic 200-level prohibitions identical to the prohibitions that exist as of 5/2019 (e.g. 560.204 (exports), 560.205 (reexports), 560.206, 560.208 (facilitation), 560.201 (imports)). The "Berman Amendment" informational materials exemption (560.210(c)) and related definition (560.315) interpreted are also essentially identical to the present versions.
2) STUDIES RELATED TO OWNERSHIP, CONSTRUCTION AND OPERATION OF THE PIPELINE
The first issue treated is an...