Case No. IA-9398

Date issued: Aug. 24 2009

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TURBOFAC Commentary (341 words)

Notes:

1) For commentary on this guidance letter in the context of other Research System letters dealing with this topic, see General Note on U.S. Organizations Providing Membership and Related Benefits to Sanctioned Persons (System Ed. Note).

2) Vis-à-vis the corpus of membership-related guidance letters discussed in the System Note referenced above, Case No. IA-9398 is notable for the statement that “allowing Iranian members to use the [American Chemical Society’s] name and logo in the formation of new chapters, may constitute the prohibited exportation of services” that require a license. This stands in contrast to OFAC’s determination in Case No. IA-6489 that a USP may allow a pre-sanctions “chapter” of its organization to continue to exist without implicating the broad prohibitions of the ITR....