Case No. IA-2013-304698

Date issued: Sep. 17 2013

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TURBOFAC Commentary (406 words)

Notes:

1) Notable amalgamation of three distinct general licenses. 560.510 (pertaining to legal disputes) allows for the engagement of Iranian lawyers and other transactions needed to carry out a legal proceeding in Iran (imports of services (560.201)). 560.543 permits services related to the sale of the property once recovered, and 560.516 allows for the transfer of the proceeds from the sale to the U.S. as ordinarily incident to the sale of the property.

2) Note the interpretation of 560.510(c)(1) as interpreting "abroad" to include Iran itself. This is not totally evident from a reading of 560.510(c)(1) in conjunction with (c)(2).

3) The GOI was blocked as of the time this letter was written.

560.510(c), which was in place long before the ITSR...