As discussed on Monday's call, the plan is to submit the OFAC Recommendation for consideration by the Plenary in next week's call. The document deadline for next week's plenary is 23:59 UTC on Wednesday, September 20.

As promised on Monday's call, I revised the draft recommendation in Google Docs to reflect the discussions on the call and then circulated PDF and Word copies to the list for review and comment. I received comments from Milton Mueller on the list, which were consistent with the Monday call, and the draft has been updated with these comments.

I am attaching PDF and Word copies of the latest version of the OFAC Recommendation, which I believe is very close to final form. I have included a clean copy of the proposed final version, and a version with track changes, showing the changes to the pre-call version of the Recommendations. IF you want to read the Recommendation, I think the clean version is much easier to follow. The track changes version is useful if you want to see what changes are made.

So that we may have a Google Doc that shows the proposed final OFAC Recommendation as it will be submitted (i.e., without revisions and comments), I have created a new Google Doc, which I encourage you all to read over one more time before it goes to the plenary. The link is:
https://docs.google.com/document/d/1xLDx7IevK2s7yQ1naD3cjnlPGnO7oPrRUN61RKEesFc/edit?usp=sharing

The marked-up version and all prior drafts are still available at the link previously circulated.

If there are any further refinements, corrections, etc., please put them into new, clean version on Google Docs, or add them to the clean document attached here and send it back to the list.

Thanks!

Greg