Case No. IA-2017-341518-1

Date issued: Jul. 26 2019

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TURBOFAC Commentary (234 words)

Notes:

1) Membership as Exempt

This guidance letter is notable primarily for the acknowledgement that (at least under certain circumstances) the provision of “individual memberships…to individuals in Iran” in the International Association of Operative Millers can be exempt from regulation. Compare generally General Note on U.S. Organizations Providing Membership and Related Benefits to Sanctioned Persons (System Ed. Note). It is likewise the case that “payment of membership fees associated with these [exempt] benefits” requires no license. The other guidance letters referenced in that System Note are consistent with the notion that membership for sanctioned persons can be exempt from regulation under the informational materials exemption, but this is highly circumstance-dependent. As of the date of this writing, this letter is the most recent guidance letter issued in the Iran context confirming that “membership” can be exempt.

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