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Case No. IA-2017-XXXXXX-1
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Washington, DC
Dear Mr. [ ]
This is in response to your request dated March 9, 2017 (the "Application") submitted on behalf of [U.S. person entity] and its employees, independent contractors, or agents to attend and present at a conference in [third country] taking place from [start and end dates] titled “[name of conference] Iran" (the "Conference"). The Conference is being held by [third country university] and is being sponsored by the university, [non-sanctioned third-country entity 1], and [non-sanctioned third-country entity 2]. The audience will include students, lawyers, business representatives, and social and political scientists, in addition to possibly Iranian government officials and employees. Additionally, scheduled speakers at the Conference include the Iranian Ambassador to [third country] and possibly an Iranian Foreign Ministry official. Finally, the Application states that...
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1) OFAC determines that 560.554(b) of the ITSR does not authorize "presenting" at a third-country conference attended by persons ordinarily resident in Iran; at least when such presentation is unrelated to “sponsoring”. Contrast Case No. IA-16912, which indicates that 560.554(b) covers "presenting" a course, but in that context there was a "sponsoring" element to the proposed activities. Refer generally to General Note on Conferences and Live Exchanges of Information (System Ed. Note) and Associated Scenario Matrix.
2) Note that OFAC also asserts jurisdiction over a U.S. person “attending” a conference in a third country at which an Iranian person is presenting. This appears to be the only item in the Research System in which OFAC does so, but others suggest that attendance of sanctions-implicating conferences (in...