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) Applicant U.S. person (BioAgilytix) asks if it can enter into a non-disclosure agreement for what appears to be a set of transactions whereby it would import “chemical compounds” presumably from Iran, and return the compounds with “data and qualitative findings regarding its analysis.” While a substantial portion of the first paragraph of the letter is redacted, the totality of the letter would not make much sense if the import and export of the “chemical compounds” were not from/to Iran. OFAC cites the medicine-related GL at 560.530(a)(3) of the ITSR as a relevant provision, and that authorization covers “conduct of related transactions” with respect to exports of “medicine to Iran,” but OFAC ultimately determines that “the performance of bioanalytical laboratory services…do not constitute the ‘conduct of related transactions’ within the...