OFAC Interpretive Ruling - 040405-FACRL-IA-15 - Publishing Activities Involving Manuscripts from Sanctioned Countries

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TURBOFAC Commentary (660 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 (FACRL IA-15, IA-16 and GN-01) from April - July 2004 that expanded the scope of the Berman Amendment vis-a-vis a series of rulings from September 2003 (FACRL-IA-09, 10 and 11). The three 2003 rulings were removed as a result of the three 2004 rulings. In 2016, OFAC issued its revised publishing guidance that superseded this guidance in particular, with knock-on effects for the other two 2004 rulings, both of which were subsequently removed from OFAC's website. Our comments sections to each of the letters discusses their continued relevance. This guidance has been explicitly overturned, but its contents remain of note since items listed as permissible here but absent from the 2016 guidance are likely...

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040405-FACRL-IA-15 - Publishing Activities Involving Manuscripts from Sanctioned Countries - Multiple; FAC No. IA-209747-a

TURBOFAC Commentary (660 words)