PRINT
Case No. IA-10419
Mr. [ ]
Buchanan Ingersoll & Rooney, PC
550 Broad Street, Suite 810
Newark, NJ 07102-4582
Dear Mr. [ ]:
This responds to your letter dated February 21, 2008, to the Office of Foreign Assets Control ("OFAC"), on behalf of the CFA Institute (the "Organization"), requesting interpretive guidance regarding the extension of membership, membership services, and testing services to individuals who reside in Iran. You describe the Organization as a membership association that provides certain advanced accreditation and continuing education services to individuals in the financial and investment professions worldwide. As stated in your application, the Organization received eight applications from individuals with preferred mailing addresses in Iran, whom you refer to as the Identified Persons.
According to your request, the following services and information are provided to individuals seeking...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
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...