Sent: Monday, March 25, 2019 7:04 PM
To: [***]@dhl.com>
Cc: OFAC_Feedback
Subject: RE: DHL Express
Travis:
Attached please find a signed Pre-Approved DHL Webship Form. Please advise as to how we should proceed in order to ship our legal documents to Iran as discussed.
Thank you,
[***]
------------------------
From: [email protected]
Sent: Wednesday, March 27, 2019 4:47 PM
To: [***]
Cc: [email protected]; [***]
Subject: RE: DHL Express
The shipment of the pre-existing legal documents would be covered under the exemption for information materials. This is provided in the following section of the regulations with a copy of the link provided below...
1) This query to the OFAC Compliance Hotline involves (see PDF) the mailing of a U.S. federal court complaint and summons to the Central Bank of Iran through the Ministry of Foreign Affairs in Iran. The law firm representing the plaintiffs asks DHL (U.S. subsidiary of a German-headquartered shipping company) for details concerning shipment with the OFAC Compliance Division in cc, and the OFAC Compliance first responds to state that “shipment of the pre-existing legal documents would be covered under the exemption for information materials”. Compare Examples of Transactions Exempt as Incident to Underlying Informational Materials Transactions. This is a notable interpretation of the informational materials exemption as it is the only one on file that addresses an actual shipper of goods’ (not just a person sending the goods) activity as exempt from regulation.
2) OFAC’s response is also...