Case No. IA-2018-351723-1

Date issued: May. 15 2018

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TURBOFAC Commentary (903 words)

Notes:

* For commentary on this guidance letter in the context of other Research System letters dealing with this topic, see General Note on U.S. Organizations Providing Membership and Related Benefits to Sanctioned Persons (System Ed. Note).

1) The relationship between sanctioned person membership in U.S. person professional/sporting organizations and the “informational materials” exemption

This letter and Case No. CU-XXXX-XXXXX-1 (11/21/2019) are the most recent guidance letters on file that address the relationship between “informational materials” and the admitting of sanctioned persons to professional/sporting organizations run by U.S. persons (or in the case of the CACR, “persons subject to U.S. jurisdiction”). Compare 031103-FACRL-IA-15a (2003, interpretive ruling removed from OFAC’s website) and Case IA-6489 (2005).

In 031103-FACRL-IA-15a and Case IA-6489 (2005), OFAC addresses the relationship between the