Case No. MUL-2022-904838-1 (Revised)

Date issued: Nov. 08 2024

Last substantive commentary amendment:
Nov. 13 2024

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TURBOFAC Commentary (1607 words)

Consolidated comment on Case No. MUL-2022-904838-1 (Revised) and Case No. MUL-2022-904838-1 (Original).

1) BACKGROUND

On April 25, 2022, The Foundation for Global Political Exchange, Inc. (“GPE”), a U.S. person entity (https://projects.propublica.org/nonprofits/organizations/843833345), requested guidance to confirm that it could have five individual speakers speak at its “Beirut Exchange Summer 2022” conference. See application at p. 7, PDF. The application stated that GPE was organizing the conference without payments being made to the speakers. Note that while the application states that the blocked speakers would not receive any sort of fee to speak, the U.S. person organizing the conference was charging a substantial fee to attend (see https://web.archive.org/web/20220408132006/https://www.globalpoliticalexchange.org/beirut). The fee charged by the applicant may have been the subject of the "supplemental correspondence" referenced in the guidance letter but not included in the PDF....