General Note on U.S. Organizations Providing Membership and Related Benefits to Sanctioned Persons (System Ed. Note)

Last substantive commentary amendment:
Jan. 02 2024

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TURBOFAC Commentary (2421 words)

General Note on U.S. Organizations Providing Membership and Related Benefits to Sanctioned Persons (System Ed. Note)

1) BACKGROUND

In the interpretive ruling 031103-FACRL-IA-15a (November 3, 2003), which was removed from OFAC’s website shortly after the release of the 2016 Publishing Guidance, OFAC addressed the relationship between the ITR as it existed in 2003 and a professional organization providing membership and other benefits to sanctioned persons. As of 7-27-23, OFAC has not provided any other form of public-facing guidance directly addressing the topic, but a number of interpretive guidance letters in TURBOFAC, discussed below, are relevant.

They are as follows:

(i) Case No. IA-6489 Institute of Electrical and Electronics Engineers (IEEE);
(ii) Case IA-8039 Institute of Electrical and Electronics Engineers (IEEE);
(iii)