§542.526 Exportation of services related to conferences in the United States or third countries authorized.
(a) The exportation, reexportation, sale, or supply of services from the United States or by a U.S. person are authorized where such services are performed or provided in the United States by or for a person who is ordinarily resident in Syria, other than the Government of Syria or any other person whose property and interests in property are blocked pursuant to §542.201(a), is authorized, for the purpose of, or which directly relate to, participating in a conference, performance, exhibition or similar event, and such services are consistent with that purpose.
(b) To the extent not otherwise exempt from the prohibitions of this part, the exportation, reexportation, sale, or supply of services directly related to the sponsorship by a U.S. person of a conference or other similar event in a third country that...
2) The precise scope of this GL, and its ITSR analogue (560.554), is particularly difficult to pin down because of the facts that i) activities related to conferences are only prohibited insofar as they constitute "services," which has become an increasingly vague concept as it relates to all interactions with sanctioned parties, and ii) because the scope of what could be prohibited as a "service" can, depending on the context, be delimited by all three of the applicable Berman Amendment exemptions all of which themselves have uncertain boundaries. Accordingly, this GL is one of the rare occasions on which OFAC recognizes that the scope of the GL touches on activity some of which is likely to be exempt from regulation.
For example, a "conference" for which payment...