OFAC Interpretive Ruling - 031014-FACRL-IA-10 - Exchange of informational material with Iranian author

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TURBOFAC Commentary (396 words)

Notes:

As discussed in the "General Background Note on the Chronology of Guidance and interpretive Rulings Related to the Informational Materials Exemption and Publishing", this is one of the three interpretive Rulings from September, 2003 (030915-FACRL-IA-09, 031014-FACRL-IA-10 and 031002-FACRL-IA-11) that were removed from OFAC's index of interpretive rulings as a result of OFAC's April - July, 2004 expansion of the scope of the Berman Amendment through 040405-FACRL-IA-15, 040706-FACRL-IA-16 and 040719-FACRL-GN-01.

Parts of this particular guidance were effectively overruled by 040706-FACRL-IA-15, which OFAC's 2016 Publishing Guidance itself overruled, appearing to turn the substantive clock back to the time at which this guidance, which takes a narrower view of the scope of the Berman Amendment, was OFAC's prevailing view. The 2016 guidance lists the following as permitted copy-editing activities, while declining to say what is prohibited:
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031014-FACRL-IA-10 - Exchange of informational material with Iranian author

TURBOFAC Commentary (396 words)