[E-trademarks] Licensing of trademark in Iran

[Pamela Chestek]

Client owns a trademark registration in Iran (lawful per 31 CFR 560.509).

Can Client license that trademark, royalty-free, to someone in Iran, or 
would that be contrary to the sanctions? If yes or no, a citation in 
support would be wonderful. I have been reading 31 CFR part 560 but 
haven't found a clear answer one way or another. 31 CFR 560.204 says 
that the "the exportation, reexportation, sale, or supply, directly or 
indirectly, from the United States, or by a United States person, 
wherever located, of any goods, technology, or services to Iran or the 
Government of Iran is prohibited," but I wouldn't consider the grant of 
a license "goods, technology or services."

Thanks,

Pam

Pamela S. Chestek
Chestek Legal
300 Fayetteville Street
Unit 2492
Raleigh, NC 27602
pamela at chesteklegal.com
(919) 800-8033
www.chesteklegal.com