Case No. SY-2017-341037-1

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.

TURBOFAC Commentary (399 words)

Notes:

1) As described in the guidance letter, 542.207 prohibited all the exportation of all “services” to Syria, while 542.510(b) authorized the “exportation, reexportation, sale, or supply, directly or indirectly, from the United States or by a U.S. person, wherever located, to Syria…of services that are ordinarily incident to the exportation or reexportation of items to Syria, or of services to install, repair, or replace such items…” Notably, this authorization is broader than all transactions ordinarily incident to underlying exports; the “services to install, repair, or replace” authorization extends beyond that which “ordinarily incident” covers where “install, repair, or replace” is not specified. The guidance request involves the following activities related to items described in 542.510(b): “1) repair and warranty services; 2) clinical technical support and quality assurance services; 3) product management and market support services; and 4) services related to training medical professionals in...

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Case No. SY-2017-341037-1

TURBOFAC Commentary (399 words)