31 CFR § 515.581 - Transactions related to conferences in third countries.

Date issued: Nov. 09 2017

Last substantive commentary amendment:
Jan. 02 2024

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TURBOFAC Commentary (394 words)

Notes:

1) Compare with SySR (542.526) and ITSR (560.554) analogues.

2) The brevity of this GL leaves open certain interpretive questions, even beyond the inherent difficulty in pinning down how, precisely, various activities pertaining to "conferences" implicate 200-level prohibitions.

The main question is whether the use of the passive voice "that are attended by Cuban nationals" is meant to limit the scope of the GL only to "attendance." The SySR analogue, for example, states that the GL applies insofar as "the conference or other similar event is not tailored in whole or in part to or for Syria or persons who are ordinarily resident in Syria." One could read the lack of that proviso in a GL issued subsequent...