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Case No. IA-2012-293254-1
Mark Wasden, Esq.
King & Spalding LLP
1700 Pennsylvania Ave., N.W., Suite 200
Washington, D.C. 20006
Dear Mr. Wasden:
This responds to your letter of March 29, 2012, on behalf of the American National Standards Institute ("ANSI"), requesting guidance from the Office of Foreign Assets Control ("OFAC"), and to additional correspondence dated March 30, 2012, from the International Organization for Standardization ("ISO") and April 4, 2012, from the National Institute of Standards and Technology of the U.S. Department of Commerce, in support of ANSI's request. In your letter, you request guidance on the applicability of the Iranian Transactions Regulations, 31 C.F.R. Part 560 (the "ITR"), to transactions by U.S. persons engaged in standards development activities with international organizations in which Iranian entities may also be involved. According to your letter, ANSI is a private,...
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1) Gen. Note on the 2012-2018 ANSI/API Correspondence: This guidance is the first of six items from OFAC that all stem from the same applications. In 2012, American National Standards Institute ("ANSI"), requested guidance on standards-setting activities and works related thereto under the Berman Amendment and Publishing GLs for multiple countries. OFAC replied in 2012 with Case No. IA-2012-293254-1 (application included in relevant PDF), and that reply prompted a request for clarification from the American Petroleum Institute, to which OFAC responded in 2014 (Case No. MUL-2012-298212-1) in a way that appeared to dampen the impact of the 2012 guidance to ANSI. ANSI then reacted to that with another request for guidance in 2015 (application included in relevant PDF) which was responded to from 2016 through 2018 in four parts, one for each embargoed country addressed (Case No. IA-2015-318205-1 [Iran], Case No. SU-2015-323915-1- [Sudan], License No....