LICENSE No. IA-2018-350420-1

Date issued: Mar. 06 2018

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TURBOFAC Commentary (161 words)


1) Compare Case No. IA-2016-325474-1. Travel to Iran to for professional conferences is ordinarily not exempt from regulation through a combination of the travel and informational materials exemptions.

Note, however, that the authorization section does not impliedly speak to the open question as to whether, and under what circumstances, the mere “passive attendance” at conferences is sanctioned countries exempt as incident to the importation of informational materials (i.e. where the materials presented are not created or substantively altered at the behest of or for the benefit of any U.S. person, and where the U.S. person does not create information or informational materials at the behest of any sanctioned person, e.g. by preparing slides or engaging in Q&A sessions).

Here, what is licensed is “participate in and attend the 5th International Congress on Cochlear Implant and Related Sciences from May 9- 11, 2018...