OFAC Compliance Correspondence in re: Shipment of Legal Documents to Iran

Date issued: Mar. 27 2019

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TURBOFAC Commentary (350 words)

Notes:

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...