Case No. IA-2017-XXXXXX-1 (2017; Response to March 9, 2017 Application)

Date issued: Mar. 24 2017

Last substantive commentary amendment:
Jan. 02 2024

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TURBOFAC Commentary (201 words)

Notes:

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...