PRINT
Case No. IA-2014-314663-1
Mary Kay Ellis
Director, Export Control Program
University of Arizona
1618 E. Helen Street
Tucson, AZ 85719
Dear Ms. Ellis:
This is in response to your request dated November 18, 2014 (the "Application"), on behalf of the University of Arizona (UA), to the Office of Foreign Assets Control (OFAC). Specifically, you are requesting authorization to allow Esmaeil Saberi, [ ], to spend time at UA as a visiting scholar conducting research on citrus greening disease.
The Iranian Transactions and Sanctions Regulations (31 C.F.R. Part 560) (ITSR), generally prohibit the importation into the United States of any goods or services of Iranian origin or owned or controlled by the Government of Iran. ITSR, § 560.201. The ITSR also generally prohibit the exportation, reexportation, sale, or supply of any goods, technology,...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
Case No. IA-2014-314662-1 and Case No. IA-2014-314663-1 are similar guidance letters, with similar applications, that were issued and applied for on the same day.
OFAC’s conclusions are notable in light of the associated applications. One application specifies that the Iranian at issue, who appears to be attempting to come to U of A on a visa category J visa, works for an Iranian university, but is also employed by an entity in Iran, and that entity in Iran will be paying all “travel and living expenses”. The other application notes that the Iranian at issue “received a six month fellowship from the “Ministry of Science of Technology” in Iran.
In both cases, OFAC finds that the proposed activities can fall within the scope of 560.505 as the