PRINT
Case No. MUL-2022-904838-1
The Foundation for Global Political Exchange, Inc.
c/o Joshua Andersen
Scientia Guidance
10A Clandon Rd.
Guildford GU1 2DR
United Kingdom
Mr. Andersen:
This responds to your application dated April 25, 2022 and supplemented on June 23, 2022 (together, the “Application”), submitted on behalf of The Foundation for Global Political Exchange, Inc. (“GPE”), to the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). According to the Application, GPE requests authorization to include five specially designated individuals as speakers at the 21st Beirut Exchange Summer 2022, which was rescheduled to December 4-10, 2022 (the “Conference”). The proposed speakers for the Conference include Usama Hamdan, who OFAC has designated as a Specially Designated Global Terrorist (“SDGT”), Ammar Moussawi and Ali Fayyad, representing Hizballah in their capacities as Hizballah leaders...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
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...