Department of State: State Department Sanctions Information and Guidance (Public Notice 8086) (2012)

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 (335 words)

Notes:

1) Published in the FR at 70 FR 38565, this "policy guidance" document contains a number of statements amounting to secondary sanctions interpretive guidance that appear to be current. Most of it, however, merely summarizes the state of the law as it existed at the time, and the relationships between the varying overlapping secondary sanctions authorities.

2) On the , note that the guidance document invites requests for advisory opinions (as specified in section 7 of the ISA), and says where they may be directed (the State Department's Office of Sanctions Policy and Implementation in the Bureau of Economic and Business Affairs at [email protected] or at (202) 647-7489).

3) The document provides guidance on the meaning of terms contained in 13590, which was revoked in connection with the

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Department of State: State Department Sanctions Information and Guidance (Public Notice 8086) (2012)

TURBOFAC Commentary (335 words)