Case No. IA-2014-311803-1
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Columbia Center
701 Fifth Ave., Suite 6100
Seattle, WA 98104-7043
Dear Mr. [***]:
This responds to your request dated July 1, 2014 and supplemental correspondence dated March 10, 2015 (collectively, the “Application”), submitted on behalf of the Institute of Electrical and Electronics Engineers (IEEE) to the Office of Foreign Assets Control (OFAC) requesting an advisory opinion as to [***]. You represent that the IEEE is a global non-profit professional association with members from around the world including certain distinguished members referred to as [***].
As you know, the ITSR generally prohibit the exportation, reexportation, sale, or supply of any goods, technology, or services, directly or indirectly, from the United States or by a U.S. person, wherever located, to Iran or the Government of Iran. ITSR, § 560.204. In addition,...
1) OFAC states that “a U.S. person presenting at a conference in Iran, regardless of whether the presentation is based on informational materials that are exempt from the ITSR’s prohibitions, would constitute a prohibited exportation of services to Iran that would also be outside the scope of the general license set forth in section 560.554 of the ITSR”. OFAC suggests that the basis for this determination is the “fully created and in existence” limitation to the informational materials exemption, which is cited in the third paragraph after the reference to the travel exemption. Compare Case No. IA-2016-325474-1, and comments thereto (“attendance at and participation in conferences in Iran, including the presentation of academic papers in Iran based on published materials that are from open and public domain literature, as described in...