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Case No. CU-2017-344688-1
[ ]
Pierce Atwood LLP
1875 K Street NW Suite 700
Washington, D.C. 20006
Dear Ms. [ ]:
This responds to your request, on behalf of ORCID Inc., dated May 15, 2017, seeking guidance, or in the alternative, a specific license, related to certain proposed transactions under the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (CACR).
As described in your request, ORCID, a U.S. 501(c)(3) non-profit organization, provides a unique, name-associated identifier ("ORCID iD") for researchers and others in the scholarly community engaged in scientific research and scholarship to search the ORCID registry. For an annual fee, subscriber organizations also have access to an application programming interface, which facilitates registration, deposit, and updating of data in an ORCID record, reading other ORCID users' data, technical support, assistance integrating ORCID...
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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...