OFAC Interpretive Guidance - Case No. IA-2012-298076-1

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TURBOFAC Commentary (1625 words)

Notes:

1) BACKGROUND

There are a few notable background facts underlying this request for guidance. First note that the Airbus 320 is a twin-engine aircraft, with a unit cost of around $100m (2018 dollars) [1], that runs on engines of both U.S. and non-U.S. origin [2]. The engines for these planes cost around $10m, so a plane running on two U.S. origin engines will always be subject to the and 560.205, given that engines are -listed items and the product into which they are incorporated will exceed 10% of the value of the finished product.

Relatedly, has initiated enforcement actions—both prior to and subsequent to the request for guidance—on the basis of foreign-made planes incorporating U.S. origin engines being sent...

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Case No. IA-2012-298076-1

TURBOFAC Commentary (1625 words)