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November 8, 2024
Case No. MUL-2022-904838-1
The Foundation for Global Political Exchange, Inc.
c/o Joshua Andresen
Scientia Guidance
50 St. Mary's Road
Hemel Hempstead
HP2 5HL
United Kingdom
Mr. Andresen:
This letter revokes the December 6, 2022 denial of 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" or the "Foundation"), to the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") (Case No. MUL-2022-904838-1).
According to the Application, GPE is a U.S.-registered non-profit organization that organizes various "Exchanges," i.e. small group, direct engagement conferences focused on the political dynamics of a specific country or region. GPE organizes the Exchanges on its own initiative, seeking to engage participants-including journalists,...
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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....