Case No. ICC-EO14203-2025-1429692-1 [Application included]

Date issued: Oct. 12 2025

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TURBOFAC Commentary (695 words)

Notes:

1) Compare Case No. MUL-2022-904838-1 (Revised) and Case No. IA-2019-362796-1. This is the most recent version of a formal interpretive guidance letter confirming that a U.S. person can host an SDN to speak at a conference in the absence of any authorization for such activities.

2) In Case No. IA-2019-362796-1, OFAC cites the informational materials exemption (and travel exemption), and concludes that “no further authorization from OFAC is required” to host the SDN for a speech. This was ambiguous as to whether OFAC regarded the activities within the scope of any prohibition to begin with. In Case No. MUL-2022-904838-1 (Revised), OFAC cited the personal communications and informational materials exemptions and ultimately determined that “actions ordinarily incident to facilitating [SDN] participation as speakers…is not a service prohibited by U.S. sanctions...