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LICENSE No. IA-2015-316156-1
IRANIAN TRANSACTIONS AND SANCTIONS REGULATIONS
LICENSE
(Granted under the authority of one or more of 22 U.S.C. §§ 2349aa-9, 8501-51, 8701-85, 50 U.S.C. §§ 1601-51, 1701-06, Executive Orders 12957, 12959, 13059, 13599, and 13628, and 31 C.F.R. Parts 501 and 560.)
To: University of California San Diego
9500 Gilman Drive #0910
La Jolla, California 92093
Attn: Brittany Whiting
1. Based upon your request dated January 20, 2015, to the Office of Foreign Assets Control (the "Application"), the transactions and activities delineated herein are hereby authorized.
2. This License is granted upon the statements and representations made in the Application or otherwise filed with or made to the Treasury Department as a supplement to the Application, or is based on information otherwise...
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1) This specific license (with associated application) illustrates OFAC's favorable licensing policy for academic work in Iran, and at the same time illustrates the limits of the scope of the GL (560.538) for "transactions necessary and ordinarily incident to publishing". According to the application, the applicant was "requesting a license to cover activities in Iran for the next two years and an additional two years for publication submission and approval." OFAC did not license "publication submission and approval," given 560.538 and the fact that publication is not prohibited by the ITSR unless it actually involves Iran-related transactions. It would not have necessarily been a stretch to consider the activities authorized here to constitute “[o]ther transactions necessary and ordinarily incident to the publishing and marketing of written publications” for the purposes...