PRINT
Case No. IA-2013-300704-1
[ ]
President
Farbell International
366 Margarita Drive
San Rafael, CA 94901
Dear [ ]
This responds to your letters of February 20, 2013, and August 12, 2013 (the "Application"), to the Office of Foreign Assets Control ("OFAC"), on behalf of Farbell International ("Farbell"), requesting authorization to facilitate the export of medicine, medical supplies and equipment, and baby formula to Iran by receiving payment for such exports from proceeds of Iranian oil exportation that are held in accounts at non-Iranian foreign financial institutions. Based on your application, Farbell is a California-based firm engaged in the import/export of medical supplies. You state that in light of U.S. sanctions policies against Iran and their impact on international banking, exporters of food, medicine, and medical supplies are having a difficult time arranging financing for these...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
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...