Case No. IA-2012-295053-1

Date issued: Oct. 04 2012

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TURBOFAC Commentary (124 words)

Notes:

1) OFAC considers "loans" (as opposed to "gifts") to fall outside of the scope of the general license for personal remittances, even where the loans are non-commercial in nature and from a parent. This seems not to have changed in light of the new general license for remittances (§ 560.550). (see Case No. IA-2012-298985-1).

*Note to all letters referencing "General License B": General License B to EO 13599 was issued concurrent with the blocking of all Iranian financial institutions. It permitted remittances involving blocked banks other than those blocked pursuant to another part of the CFR (i.e. WMDPSR or GTSR). The reissue of the