Case No. IA-2012-299845-1

Date issued: May. 06 2013

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TURBOFAC Commentary (617 words)

Notes:

1) The application contemplates the export of a service “to Iran” by virtue of the recipient being an entity organized under the laws of Iran (560.204/560.410). Here, OFAC says that U.S. lawyers may provide sanctions related advice in connection with prospective commercial transactions directly to an Iranian entity (and even persons blocked under the ITSR, including the Government of Iran). Compare with OFAC's 2017 "Guidance on the Provision of Certain Services Relating to the Requirements of U.S. Sanctions Laws." Unlike the Compliance Services Guidance, the legal advice GL allows for direct relationships with prohibited parties, so long as they are the actual direct or indirect recipients of the legal advice. Presumably, the sort of solicitation of information in connection with the advice that would be considered an “import”...