Hi Adrian >> Legally required disclosure >> We may at times be required by law to release Non-Public Information, and we will do so if we believe in good faith that such release is required by applicable law, regulation or judicial order. > I think I was surprised that US law requires you to check the sanction list for meetings held overseas. I suppose this is because the place of business of the LLC is the US. I’m not questioning who is on the US sanctions list, only pondering how the way we are set up commercially forces us to be subject to the vagaries of US law. It is certainly an uncomfortable truth. The flip side, of course, is that no one is in a position to gripe about other countries we might decide to meet in applying their own checks against sanction lists. Just to be clear, we are only doing name matches and the names of meeting participants is public data. > Can you tell us whether the check against the US sanctions list is push or pull? That is, do you supply details to the USG for them to verify non-sanctioned status, or is there a list of sanctioned individuals that you check against? The US OFAC system [1] has changed multiple times, so I will need to check how we do it now. Jay [1] https://ofac.treasury.gov/sanctions-list-search-tool -- Jay Daley IETF Executive Director exec-director@xxxxxxxx
