Case No. IA-2020-368922-1 [Application included]

Date issued: Feb. 18 2022

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.

TURBOFAC Commentary (379 words)

Notes:

1) This guidance letter contains a notable interpretation of the scope of the standard GL for publishing (here 560.538). CUNY writes on behalf of an Iranian national that is present in the U.S., and as a result is a U.S. person generally prohibited from exporting or importing services to and from Iran. The question is whether the publishing GL covers "sit[ting] on the editorial board of two scientific journals [] published in Iran". OFAC concludes that, to the extent the editorial board-related activities are not exempt altogether, they qualify for the publishing GL. It is not clear whether the basis for this is 560.538(a)(2) (Collaborating on the creation and enhancement of written publications), or the catch-all at 560.538(a)(7) "Other transactions necessary and ordinarily incident to the publishing and marketing of written publications as described in [560.538(a)]." The task of individuals sitting...