Case No. IA-2013-300704-1

Date issued: Sep. 30 2012

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TURBOFAC Commentary (540 words)

Notes:

1) An apparent early attempt at the establishment of a "humanitarian channel" for the exportation of agricultural goods and medical supplies, deemed necessary by some in the private sector as a result of many commercial banks refusing to process transactions involving Iran even where such transactions are exempt from regulation or otherwise authorized by OFAC.

2) Not that it would have made a difference, but note that this request was sent prior to the 31 March 2014 amendment to the ITSR providing that "[s]pecific licenses may be issued on a case-by-case basis to permit U.S. persons to provide brokerage services on behalf of non-U.S., non- Iranian persons for the sale and exportation or reexportation of agricultural commodities to the Government of Iran."

What the U.S. person applicant was asking for here, however, was...