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Case No. MUL-346-1
[***]
[***]
Columbia Center
701 Fifth Avenue, Suite 6100
Seattle, WA 98704
Dear Mr. [***]:
This responds to the application dated October 29, 2010 and supplemental correspondence dated April 12, 2011 and September 19, 2013 to the Office of Foreign Assets Control (OFAC), on behalf of the Institute of Electrical and Electronics Engineering (IEEE), requesting guidance involving certain activities of the IEEE under the Cuban Assets Controls Regulations, 31 C.F.R. part 515 (CACR), the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), and the Sudanese Sanctions Regulations, 31 C.F.R. part 538 (SSR).
As previously provided to you in your correspondence on behalf of IEEE under Case No. SU- 2014-309594-1, on January 13, 2017, OFAC issued an amendment to the SSR by adding section 538.540. This new general license authorizes...
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1) Compare generally General Note on U.S. Organizations Providing Membership and Related Benefits to Sanctioned Persons (System Ed. Note). Here, as is the case with a number of other guidance letters issued around this time period, OFAC confirms that no license is required for “the extension of membership to and acceptance of annual dues from Iran an in connection with receipt by Iran an of publications and information” (though other types of services require a license). OFAC appears to confirm that 031103-FACRL-IA-15a remains valid with respect to the quoted text notwithstanding that it was removed from OFAC’s website (consistent with Case No. IA-2014-311803-1, the overruled portion of 031103-FACRL-IA-15a appears to be a paragraph dealing with conferences).