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.
1) Compare/read in conjunction with Case No. CU-2016-331352-1 and comments thereto. This is very similar except that the authorizing GL cited is different. 515.577 is the CACR publishing GL.
2) The beneficiary to this wire is Casa de las Americas (evidently a non-government entity), while the beneficiary bank (Banco International de Comercio SA) is a Government of Cuba entity. Meanwhile, 515.577 provides that “section [515.577] does not apply if the parties to the transactions described in [515.577(a)] include the Government of Cuba.” This guidance confirms the most logical reading of that proviso, which is that the “Government of” exclusion to section 515.577 (and other publishing GLs) only applies where the government entity is a party to the actual publishing-related transactions authorized, not ancillary transactions such as payment processing (or...