Case No. IA-2012-295460-1
[ ]
American Railway Engineering and Maintenance-of-Way Association
10003 Derekwood Lane, Suite 210
Lanham, MD 20706
Dear [ ]
This responds to your letter dated June 8, 2012 (the "Application"), to the Office of Foreign Assets Control ("OFAC") requesting guidance on whether the American Railway Engineering and Maintenance-of-Way Association ("AREMA") can extend membership services and develop a collaborative relationship with the Iran Rail Transit Engineering Association ("IRTEA"), pursuant to the Iranian Transactions and Sanctions Regulations 31 C.F.R. Part 560 (the "ITSR"). You describe AREMA as a non-profit association committed to the education, development, and promulgation of standards and practices used in your field.
We understand from your Application AREMA seeks authorization to extend the following membership benefits to the IRTEA: (a) access to publications such as manuals of standards and recommended practices...
* 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) Conferences:
With respect to the question of potential in-person presentations by AREMA members at exhibitions, conferences, and seminars in Iran, the precise scope of activities discussed in the application would be helpful, but OFAC's response suggests that, as it relates to the export of services "to Iran" through face-to-face presentations at conferences in the U.S. or third countries, there is nothing covered by the informational materials exemption that 560.554 [1] does not cover.
OFAC suggests that the presentations in Iran are prohibited outright, and that presentations to persons ordinarily resident in Iran is permitted insofar as the terms of...