Case No. IA-2013-303560-1

Date issued: Jan. 07 2014

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TURBOFAC Commentary (485 words)

Notes:

1) FULLY CREATED AND IN EXISTENCE

Compare Case No. IA-2012-293259-1, which is a sort of companion case, as it relates to internet based database subscriptions and the informational materials exemption. Case No. IA-2012-293259-1 confirms that “a[] OFAC license is not required to provide subscription access to a searchable database of legal documents,” provided that the “content [is] be fully created and in existence at the time of the transmission and [] not be created at the behest of an Iranian person”. In other words, the information in the database need not be fully created and in existence as of the time of the subscription.

This letter does not directly address that issue, but it is clear that OFAC arrives at the same conclusion. The product at issue is access to an internet based database that is sold as a yearly...