Case No. SY-2019-361411-1

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 (422 words)

Notes:

1) Guidance request deals with UPS “confiscating” (presumably blocking) a parcel mailed from the Syrian embassy in Canada (Syrian government was blocked at the time) to the applicant’s brother. It reports that initially the applicant “sent mail from the United States to the Syrian Embassy in Canada for [the applicant’s brother] to renew his passport”. This may have included documents such as the old/expired passport for invalidation, application forms and other supporting documentation such as IDs. OFAC concludes that as a result of the travel exemption, “UPS may release the confiscated Package without the need for further authorization from OFAC” to the “extent the Package contains a passport or other passport-related documents pertaining to travel” because “OFAC considers activities related to obtaining and renewing passports, including such activities involving the Syrian Embassy in Canada, to be exempt from the prohibitions of the

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Case No. SY-2019-361411-1

TURBOFAC Commentary (422 words)