Case No. IA-16912

Date issued: Oct. 25 2013

Last substantive commentary amendment:
Jan. 02 2024

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TURBOFAC Commentary (486 words)

Notes:

1) While the applicant refers to "Iranian citizens," note that the proposed activity would normally only implicate the ITSR if the course participants are actually "ordinarily resident" in Iran. Many Iranian nationals live in Dubai on a permanent basis.

2) The guidance clarifies that a "six-day course in Dubai" of unspecified content falls within the scope of 560.554, which covers "public conference, performance, exhibition or similar event." A "course," here, is apparently considered a "similar event." This adds scope, beyond 560.544, which only applies to degree-granting institutions, to the range of third-country "educational activities" that U.S. persons can engage in vis-a-vis persons ordinarily resident in Iran.

3) Compare Case No. IA-2012-295460-1, dealing in part with the relationship between 560.554 and 560.210(c) (the informational materials exemptions)....