Case No. IA-10419

Date issued: Oct. 09 2012

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TURBOFAC Commentary (566 words)

Notes:

1) For commentary on this guidance letter in the context of other Research System letters dealing with this topic, see General Note on U.S. Organizations Providing Membership and Related Benefits to Sanctioned Persons (System Ed. Note).

2) Read in conjunction with 031103-FACRL-IA-15a (2003 interpretive ruling), and query whether the "U.S. Entity" at issue in that interpretive ruling is likely to be the CFA Institute. Even if it isn’t this letter and that interpretive ruling are companion cases in a sense, given the degree of factual overlap.

3) Vis-à-vis the corpus of membership-related guidance letters discussed in the System Note referenced above, Case No. IA-10419 is notable for the following reasons:

a) Membership as a “Service”

OFAC concludes that “[a]cceptance into program membership of, and membership fees from, persons...