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Case No. MUL-2014-315008-1
Linda Steinman, Esq.
Davis Wright Tremaine LLP
1633 Broadway, 27th Floor
New York, NY 10019-6708
Dear Ms. Steinman:
This is in reply to your December 3, 2014 request to the Office of Foreign Assets Control (OFAC), on behalf of your client Elsevier, Inc., for interpretive guidance on the publishing general licenses (the "Publishing GLs") and exemptions found in the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. §§ 560.210, 560.538, the Cuban Assets Control Regulations (CACR), 31 C.F.R. §§ 515.206, 515.577, the Sudanese Sanctions Regulations (SSR), 31 C.F.R. §§ 538.212, 538.529, and the Burmese Sanctions Regulations (BSR), 31 C.F.R. §§ 537.210, 537.526. [1] We refer throughout this letter to the governments of Iran, Cuba, and Sudan as "sanctioned governments." We address the BSR separately to note changes in Burma since the issuance of...
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1) For substantive analysis see comments to Guidance on Certain Publishing Activities (2016), which is essentially a de-personalized copy of this guidance, adapted for public consumption. Note that the application attached to the original PDF file of this letter is helpful context for understanding the 2016 guidance, and relays guidance from OFAC concerning the concept of "acting on behalf of" a sanctioned government.