Case No. MUL-346-1

Date issued: Sep. 29 2017

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TURBOFAC Commentary (126 words)

Notes:

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).