Case No. MUL-2022-904838-1 [Application included]

Date issued: Dec. 06 2022

Last substantive commentary amendment:
Mar. 01 2024

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (918 words)

Notes:

1) The applicant here, which is a U.S. person entity (https://projects.propublica.org/nonprofits/organizations/843833345), proposed to invite certain individual to speak at a conference it was organizing without payments being made to the speakers.

As OFAC notes in the guidance letter, one of the proposed speakers was “designated as a Specially Designated Global Terrorist,” one was “blocked by OFAC under the Global Magnitsky program,” one was “blocked by OFAC under the Lebanon program,” and two were “representing Hizballah in their capacities as Hizballah leaders and therefore also SDGTs”.

2) “Platform to speak” as a service

The applicant explicitly seeks guidance confirming that its proposed activities do not amount to the provision of a “service” to the speakers at issue. OFAC concludes that “inclusion of the Blocked Speakers in the Conference and the provision of a...