Case No. IA-2016-325474-1 [Application Included]

Date issued: May. 20 2016

Last substantive commentary amendment:
Jan. 02 2024

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TURBOFAC Commentary (1420 words)

Notes:

1) PRESENTATIONS AND TALKS “DRAWN” OR DERIVED FROM EXEMPT INFORMATIONAL MATERIALS

The letter seeks to confirm that “standard academic presentations and talks by [university] faculty members” are, themselves, exempt “informational materials” when they are drawn from exempt informational materials. Here, the subject of the conferences is civil engineering.

OFAC says that “attendance at and participation in conferences in Iran, including the presentation of academic papers in Iran based on published materials that are from open and public domain literature, as described in the Application, would be prohibited by sections 560.201 and 560.204 of the ITSR unless specifically licensed by OFAC.”

In other words, the fact that a presentation is “drawn from” pre-existing informational materials—i.e. materials fully created and in existence prior to the sanctions-implicating activities—does not mean that...