Case No. IA-2017-339679-1

Date issued: Aug. 26 2019

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TURBOFAC Commentary (1084 words)

Notes:

1) The “Personal Communications” Determination

As of 12-24-23, this is the only item in the Research System in which OFAC actually identifies a specific otherwise prohibited transaction and determines that it is exempt as a result of the “personal communications” exemption.

First, note that the applicant PMI is (“an evangelistic non-profit Christian organization”) is an “entity” for purposes of the ITSR’s definition of that term (see 560.305). Note in addition that “the pastor who founded PMI” is Donald Fareed (https://persianministries.org/about/founder.php). PMI/Fareed report that “the pastor who founded PMI uses social networking including Facebook and Twitter in addition to Skype, through both his own account and PMI’s account, to both mentor Persian Christians who contact him and non-Christians who inquire about the teachings of the Bible.” OFAC concludes that...