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 Case No. BEL-2014-313440-1 and Case No. BEL-2014-310852-1. There, as here, OFAC addresses a case where a non-U.S. entity seeks to engage in transactions that would be prohibited for U.S. persons, where the non-U.S. entity is owned by a U.S. entity. In this case, the non-U.S .entity is acknowledged as being under the “control” of U.S. persons through “ownership structure and board composition.” Even then OFAC’s guidance indicates that the non-U.S. entity being controlled by U.S. persons is insufficient to establish jurisdiction; what matters is whether “U.S. persons are involved in the transaction,” i.e. the specific sanctions-implicating transaction, rather than the general direction of the non-U.S. entity at issue. As is the case with the Belarus-related guidance letters, there is no indication that the private equity fund that owned the non-U.S. person would have needed to ensure that any profits derived from sanctions...