General Note on Conferences and Live Exchanges of Information (System Ed. Note) and Associated Scenario Matrix

Last substantive commentary amendment:
Nov. 13 2024

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TURBOFAC Commentary (4883 words)

General Note on Conferences and Live Exchanges of Information (System Ed. Note) and Associated Scenario Matrix

1) BACKGROUND

2) THE THRESHOLD QUESTION OF WHETHER CONFERENCE RELATED ACTIVITIES ARE COVERED BY OFAC’S PROHIBITIONS
a. Conferences Located in Sanctioned Destinations
b. Conferences Located in Syria as a Special Case
c. Conferences Located in the U.S.
d. Conferences Located in Third Countries that Involve Sanctioned Persons
i. U.S. Person “Organizing” and “Hosting” (with or without “Sponsoring”) of Conferences in Third Countries with a Sanctions Nexus – Generally Prohibited
ii. The Significance and Meaning of “Sponsoring” a Third Country Conference with a Sanctions Nexus
iii. U.S. Person “Presenting” (or “Participating in”) or “Attending” a Third Country Conference with a Sanctions Nexus
1. Presenting (“Participating in”)
2. Attend
3. Misc Services

3) THE RELEVANCE OF EXEMPTIONS
a. Information and Informational Materials
b. Personal Communications
c. Travel

4)...