Microsoft Corp. (2012 Correspondence With the SEC)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (821 words)

Notes:

1) This correspondence with the SEC is notable for its implications for the standard "personal communications" and the informational materials exemption as applied to internet services.

In 2009, "Microsoft...stopped offering instant messaging services to users in Cuba, Syria, Iran, Sudan, and North Korea," evidently due to sanctions concerns. (See Case No. MUL-271). This initially resulted in the issuance of the standard personal communications GLs at 560.540 of the and 538.533 of the Sudanese Sanctions Regulations.

560.540 (75 FR 11000, Mar. 10, 2010) provided (and still provides as of 3/2023) as follows:

"The exportation from the United States or by U.S. persons, wherever located, to persons in Iran of services incident to the exchange of personal communications over the Internet, such as instant...

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Microsoft Corp. (2012 Correspondence With the SEC)

TURBOFAC Commentary (821 words)