Case No. IA-2017-340755-1; LICENSE No. IA-2017-340755-1 [Application and cover letter included]

Date issued: Apr. 18 2017

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TURBOFAC Commentary (940 words)

Notes:

1) Compare Case No. IA-2013-302015-1; License No. IA-2013-302015-1, in which OFAC licenses "all transactions necessary to conduct cultural and academic field research on the influence of Information Communication Technologies (“ICTs”) on the economic, cultural, social, political, and religious spheres of life in Iran, including but not limited to, conducting surveys and interviews of activists and ordinary Iranians on their use of ICT..." That case makes clear that OFAC does not regard field research in Iran to constitute a transaction ordinarily incident to publishing, for the purposes of 560.538, even when the field research is done with an eye toward eventual publication. Compare also Case No. IA-2020-368922-1, in which OFAC says that a U.S. person can "sit on the editorial board of two scientific journals being published in Iran" under the authority of the publishing GL at 560.538....