Case No. IQ-2655; License No. IQ-843; License No. IQ-910; License No. IQ-911; License No. IQ-976; License No. IQ-1242

Date issued: Mar. 24 2005

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TURBOFAC Commentary (2081 words)

Notes:

1) The native PDF file contains Case No. IQ-2655, as well as each of the specific licenses referenced therein. At the time that the specific licenses were issued, Iraq was subject to a comprehensive embargo that, being promulgated pursuant to UNPA in addition to IEEPA, did not contain a travel exemption. The ISR as they existed on 2003-07-01 can be found at https://www.govinfo.gov/content/pkg/CFR-2003-title31-vol2/xml/CFR-2003-title31-vol2-part575.xml. This is a relatively rare set of interpretations of the scope of a specific license (being read in light of the regulations associated with the authority pursuant to which the license was granted).

2) JURISDICTION OVER “NEGOTIATIONS” AS EARLY AS 1997

The specific licenses are notable as early examples of OFAC authorizing U.S. persons to assist a non-U.S. affiliate with “negotiations” with blocked persons (here...