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Case No. IA-6489
MAY 9 2005
[ ] Esquire
Dorsey & Whitney LLP
U.S. Bank Centre
1420 Fifth Avenue, Suite 3400
Seattle, WA 98101-4010
This responds to your letters of July 26, 2004, and January 20, 2005, on behalf of the Institute of Electrical and Electronics Engineers, Inc. ("IEEE"), an educational and scientific not-for-profit organization, requesting an interpretation of the Iranian Transactions Regulations, 31 C.F.R. Part 560 (the "ITR"), the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (the "CACR"), and the Sudanese Sanctions Regulations, 31 C.F.R. Part 538 (the "SSR"), with regard to five categories of IEEE's membership activities as they relate to Iran, Cuba and Sudan [1] (the "Sanctioned Countries").
New General License Applicable to Standards Development and Joint Works
With...
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* 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....