040706-FACRL-IA-16 - Translation of Informational Materials from Iran

Date issued: Jul. 06 2004

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (684 words)

Notes:

1) Refer to the "General Background Note on the Chronology of Guidance and interpretive Rulings Related to the Informational Materials Exemption and Publishing" for the status of this guidance vis-à-vis the other Berman Amendment interpretive Rulings.

2) THE STATUS OF TRANSLATION UNDER THE BERMAN AMENDMENT

This guidance was on OFAC’s website from 2004 up through soon after the 2016 Guidance on Certain Publishing Activities was released. The reason for its removal is not clear, but it should not be presumed that it was removed in connection with the reversal in policy articulated by OFAC in the 2016 Guidance on Certain Publishing Activities.

The 2016 Guidance does not discuss translation one way or the other. This guidance refers specifically to 040405-FACRL-IA-15, which was explicitly superseded by the 2016 Guidance, such that the reference to that...