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Case No. IA-9573
Daniel R. Zim, Esq.
Assistant General Counsel
American Society of Travel Agents
1101 King Street, Suite 200
Alexandria, VA 22314
Dear Mr. Zim:
This responds to your letter of June 1, 2007, and additional correspondence dated February 22, 2008, to the Treasury Department's Office of Foreign Assets Control ("OFAC"), on behalf of the American Society of Travel Agents ("ASTA"), regarding the prospect of Iranian nationals attending an annual travel industry event known as THETRADESHOW (the "Show") held in the United States. In your letter, you request interpretive guidance regarding the applicability of the Iranian Transactions Regulations, 31 C.F.R. Part 560 (the "ITR"), to activities involving travel agents and tour operators based in Iran who have been granted visas by the United States Department of State to attend the Show. You include...
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1) Read as a companion to Case No. IA-16030, another guidance letter interpreting section 560.505 of the ITR in a way that construed the U.S. conference GL, how at 560.554(a) of the ITSR, as allowing Iranians to rent exhibition space at a conference hosted in the U.S. by a U.S. person.
Section 560.505(a) (2009) of the ITR provided as follows:
“The importation of Iranian-origin services into the United States or other dealing in such services is authorized where such services are performed in the United States by an Iranian citizen or national for the purpose of, or which directly relate to, participating in a public conference, performance, exhibition or similar event, and such services...