031103-FACRL-IA-15a - Professional Membership Guidance - Iran

Date issued: Nov. 03 2003

Last substantive commentary amendment:
Jan. 02 2024

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TURBOFAC Commentary (956 words)

Notes:

* For commentary on this guidance letter in the context of other Research System letters dealing with this topic, see General Note on U.S. Organizations Providing Membership and Related Benefits to Sanctioned Persons (System Ed. Note).

1.1) General Note on interpretive Rulings Removed from OFAC’s Index: A substantial number of OFAC’s Interpretive Rulings—many of which serve as the only public statements that OFAC has ever made on certain fundamental interpretive questions with cross-programmatic implications—have been removed from OFAC’s website. With one rare exception, OFAC does not offer statements explaining why it has taken the rulings down, but in the vast majority of cases, the rulings were subsequently rendered either incorrect or confusing as a result of OFAC’s general licensing of conduct that would have been prohibited under the guidance. We include these rulings in the database because of the value they retain...