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Case No. IA-8039
AUG 1 2006
[ ]
Dorsey & Whitney LLP
U.S. Bank Centre
1420 Fifth Avenue, Suite 3400
Seattle, WA 98101-4010
Dear [ ]
This responds to your letter of December 6, 2005, to the Treasury Department's Office of Foreign Assets Control ("OFAC") on behalf of the Institute of Electrical and Electronics Engineers, Inc. ("IEEE"), a non-profit society of engineers, regarding the application of the Iranian Transactions Regulations, 31 C.F.R. Part 560 (the "ITR"), to transactions involving the presentation of a prizewinning technical paper by an Iranian national at an international conference. You state that the IEEE Communications Society (ComSoc), a key operating unit of the IEEE, invited a communications engineering student at K.N. Toosi University of Technology and a collaborator at the Iran Telecommunications Research Center in Tehran, Iran to...
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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).
1) Compare with Case IA-6489, with respect to with the request for guidance here sought clarification. This guidance makes the same point about a third party funding the travel of an Iranian being exempt under 560.210(d), except here OFAC confirms that 560.210(d) applies i) even to an Iranian traveling to a country other than the U.S., ii) where the funds transferred are reimbursements for travel-related costs that are not necessarily transportation such as travel and food (described in the letter as "reasonable out of pocket expenses").
2) In Case No. IA-6489, OFAC determines that so long as "the...