Case No. IA-6489 - [Application Included in Original PDF]

Date issued: May. 09 2005

Last substantive commentary amendment:
Jan. 02 2024

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TURBOFAC Commentary (1356 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).

STANDARDS DEVELOPMENT AND JOINT WORKS

1) Activities related to "standards development" and "joint works" described in the application were viewed as falling within the scope of the publishing general license 515.577 (since amended). Activities included collaboration in working groups with the aim of producing written standards documents, where the key to the legal analysis was OFAC's acceptance of the characterization of the standards setting process in general as something in furtherance of a final written document. For more recent guidance related to similar activities, including the intersection between standards setting activities and the publishing GLs, see Case no. IA-2012-293254, Case no....