31 CFR § 560.538 - Authorized transactions necessary and ordinarily incident to publishing.

Date issued: Oct. 22 2012

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TURBOFAC Commentary (1248 words)

Notes common to the ITSR, SYSR and CACR Publishing GLs (see below for provision-specific comments):

The ITSR, SySR and CACR GL for transactions necessary and ordinarily incident to publishing are, with some exceptions identified below, of virtually identical scope.

1) This is one of the rare GLs that contain the qualifier "[t]o the extent that such activities are not exempt from this part;" in recognition of the fact that this GL owes its existence to a lawsuit alleging that OFAC’s restrictions on publishing activities amounted to regulation ultra vires of the IEEPA/TWEA Berman Amendment (as well as unconstitutional). The activities described in this GL touch indirectly on the scope...