Case No. IA-2013-300441-1

Date issued: May. 13 2013

Last substantive commentary amendment:
Dec. 08 2023

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TURBOFAC Commentary (429 words)

Notes:

1) This fact pattern differs from the typical remittance question pertaining to Iranian nationals living in third countries. When such nationals are "ordinarily resident" in the third country, payments to or from the person do not constitute exports of financial services "to Iran" (560.204/560.410).

This one is different, however, since the inquiry concerning funds of an Iranian national coming from a third country in which that person lives where there are the additional facts of the primary party to the transaction with the U.S. person being a Dubai-based company which is owned by an Iranian national.

Because this is of a commercial nature, the remittance GL (560.550) would appear to be irrelevant to the inquiry altogether.

OFAC determines that because the owner of the company is not "ordinarily resident in Iran" by virtue of the...