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Case No. CU-2015-318654-1
Mark Wasden, Esq.
King & Spalding LLP
1700 Pennsylvania Avenue, NW
Suite 200
Washington, DC 20006-4707
Dear Mr. Wasden:
This is in reply to your January 16, 2015 request ("Application"), and additional correspondence dated March 16, 2017 and October 10, 2017, on behalf of the American National Standards Institute (ANSI) and ANSI-accredited U.S. Technical Advisory Groups (together, "Applicants"), for a specific license authorizing the Applicants to engage in standards development activities at the International Organization for Standardization (ISO) and the International Electrotechnical Committee (IEC). This letter addresses activities involving Cuba; the Office of Foreign Assets Control (OFAC) has responded separately to your requests with respect to activities involving Iran, North Korea, and Sudan.
According to your Application, ANSI is a private, non-profit membership organization and coordinator for the United States private-sector...
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1) Gen. Note on the 2012-2018 ANSI/API Correspondence: This guidance is the last of six items from OFAC that all stem from the same applications. In 2012, American National Standards Institute ("ANSI"), requested guidance on standards-setting activities and works related thereto under the Berman Amendment and Publishing GLs for multiple countries. OFAC replied in 2012 with Case No. IA-2012-293254-1 (application included in relevant PDF), and that reply prompted a request for clarification from the American Petroleum Institute, to which OFAC responded in 2014 (Case No. MUL-2012-298212-1) in a way that appeared to dampen the impact of the 2012 guidance to ANSI. ANSI then reacted to that with another request for guidance in 2015 (application included in relevant PDF) which was responded to from 2016 through 2018 in four parts, one for each embargoed country addressed (Case No. IA-2015-318205-1 [Iran], Case No. SU-2015-323915-1-...