Case No. IA-2014-314536-1

Date issued: Sep. 29 2017

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TURBOFAC Commentary (196 words)

Notes:

1) Compare Case No. DPRK2-2018-356417-1. Here, as there, OFAC confirms that “books” are generally exempt as “information or informational materials,” though “toys” are not. The letter as notable as a rare one issued to an Iranian exporter. See applicants website at https://www.bookcity.org/en/about-us.

* In various guidance letters covering a variety of informational materials-related contexts (this is one of them), OFAC has made some version of the following statement: “transactions related to the importation from any country and the exportation to any country of information or informational materials, as defined in section 560.315 of the ITSR, whether commercial or otherwise, regardless of format or medium of transmission, are exempt from the prohibitions contained in the ITSR.” “Related to” is often interpreted broadly by OFAC, i.e. more...