Case No. IA-11074

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (189 words)

Notes:

1) This application of the publishing appears to confirm that “add[ing] commentaries in English” to pre-existing would have, even prior to the 2016 Publishing Guidance, constituted the “substantive alteration” of pre-existing materials that would have been outside the scope of the informational materials exemption. This is no surprise. What is useful about the guidance is the confirmation that the exportation or other sale of materials for which the publishing GL is necessary for the creation is, itself, exempt from regulation (once the substantive alterations requiring the publishing GL are complete).

2) The guidance is also notable for the confirmation that U.S. persons may employ Iranians as consultants in connection with the translation and commentaries on pre-existing informational materials. The publishing GL explicitly references “[p]ayment of royalties for written publications” as authorized, as well as “[c]ollaborating...

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Case No. IA-11074

TURBOFAC Commentary (189 words)