Case No. IA-2023-1021671-1 [Application Included]

Date issued: Apr. 04 2023

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TURBOFAC Commentary (330 words)

Notes:

1) The applicant university asks for authorization to hire a citizen of Iran, currently residing in Canada, to teach a class “remotely from Canada”. The applicant states that the Iranian citizen “has lived in Canada since 2018” (the application was made in 2023), and that he “provided to [the U.S. university] the documentation demonstrating his Quebec permanent residency status”. OFAC notes that “Iranian-origin services [the importation of which his prohibited] include services performed outside Iran by a citizen. national or permanent resident of Iran who is ordinarily resident in Iran.”

2) OFAC concludes that “[a]s long as [the citizen of Iran] is ordinarily resident in Canada, or any other country outside Iran, he would not be considered to be ‘ordinarily resident in Iran’ for purposes of the ITSR.” This is a...