Case No. IA-2012-293096-1

Date issued: Sep. 18 2012

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TURBOFAC Commentary (379 words)

Notes:

1) Guidance issued just prior to the reissue of the ITR at the ITSR, but there is no apparent reason to believe that the results would not be the same under the current version on the sanctions.

2) The applicant has an active account at an Iranian bank designated under the WMDPSR. OFAC states that to close this account, and/or transfer the funds back to the U.S., a license would be required. OFAC cites 544.201 (the ordinary blocking regulation). 544.201(b)(2) prohibits the receipt of services from any blocked party, so it would stand to reason that, just as OFAC considers the maintenance of any account in Iran...