030424-FACRL-IA-03. Export of Services - Surveys & Interviews [Application & Correspondence obtained via FOIA included in Original PDF]

Date issued: Apr. 24 2003

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TURBOFAC Commentary (551 words)

Notes on 030424-FACRL-IA-03

1) Out of context it appears slightly odd that OFAC characterized this activity as an "export" of a service to Iran rather than an "import," but the context of the application is the Government surveying people in connection with broadcasting that it planned to do in Iran. In the context of something like marketing research, a survey would more likely be characterized as an "import" of a service "560.201."

2) The guidance clarifies, as others have, that one may "export" a service to a country even where one receives no remuneration for (or even pays for) that service, and where the service is non-economic in character.

3) Since the release of this guidance, at least one U.S. person, Pew Research Center, has conducted surveys in Iran [1]. According to Pew,

"Surveying in Iran presents special challenges, owing in part to...