February 27, 2004

Don't let me catch you editing!

I guess I've been out of touch for a little bit. Now that a few more countries are under sanctions (as Iran, Sudan, and others join Cuba), we have new rules for what you can (such as publish) and can't (such as edit) do.

From a clarifying letter on the US Treasure website (and cached locally here .

It seems that OFAC --the Office of Foreign Asset Control--has laid down guidelines for what can, and cannot, be done.

IEEE is all over this; Democracy Now claims that violations can be punishable by fines of up to half a million dollars or jail terms as long as ten years. Making Light takes it very seriously.

And Rebel Edit is publishing an online compendium of edited works. Submit your own, they suggest. Find an Iranian poem, a Cuban letter, and edit it.

I'm fascinated by this, in a worried kind of way. It hadn't occurred to me that editing, writing, publishing, and collaborating were really seperable. (In some ways, the essence of my dissertation is to cliam that most of this work is, in fact, not at all seperable, but is embedded in a socila context.)

It is absurd to imagine IEEE is "providing a service" to Iranian scientists by editing their work, but not by publishing. Is this an odd example of well-meaning beauraucratic rules gone wrong, or is it an attempt to fully isolate those scientific communities, along with the rest of the country?

It seems like a policy question that needs to be debated a little more publically.

As you know, the importation from any country and the exportation to any country of information and informational materials, whether commercial or otherwise, regardless of format or medium of transmission, are exempt from the Iranian Transactions Regulations

Nevertheless, certain activities described in your letter would fall outside of the information and informational materials exemption. The collaboration on and editing of manuscripts submitted by persons in Iran, including activities such as the reordering of paragraphs or sentences, correction of syntax, grammar, and replacement of inappropriate words by U.S. persons, prior to publication, may result in a substantively altered or enhanced product, and is therefore prohibited under ITR § 560.204 unless specifically licensed. Such activity would constitute the provision of prohibited services to Iran, regardless of the fact that such transactions are part of the U.S. Entity’s normal publishing activities. Similarly, while the U.S. Entity may select members to review Iranian manuscripts and to communicate with Iranian authors, the U.S. Entity’s selection of reviewers and its facilitation of a review by its members, wherever located, for the purpose of collaborating with Iranian authors on manuscripts resulting in substantive enhancements or alterations to the manuscript, would be prohibited.

February 27, 2004 11:06 PM | in Data and Documents
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