Case No. CU-2017-344688-1

Date issued: Apr. 20 2020

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TURBOFAC Commentary (576 words)

Notes:

1) For further background on ORCID, see orcid.org (and https://web.archive.org/web/20170602074536mp_/https://members.orcid.org/research-organizations), and for further background on INFOMED, see https://www.sld.cu/.

OFAC concludes its guidance with various sentences beginning with "to the extent that," which indicates that, based on the facts set out in the first two paragraphs, OFAC is willing to accept, in principle, that the entirety of the transactions authorized are either exempt or otherwise licensed pursuant to the broad informational materials GL at 515.545 or the standard publishing GL at 515.577. As it relates to the relationship between those two GLs, refer to Case No. CU-2015-318654-1, and comments thereto, and query whether there are any transactions authorized by 515.577 that are not also authorized by 515.545 (there are plenty of types of transactions authorized by the broader...