Case No. MUL-314-2

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 (276 words)

Notes:

1) This guidance letter illuminates several aspects of OFAC’s interpretation of the standard for IP-related transactions. The GLs at issue explicitly authorize the “maintenance of a patent, trademark, copyright or other form of intellectual property protection” (see 560.509), and, implicitly, all transactions “ordinarily incident” to such authorized transactions (560.405).

2) The first question is whether “registration and management of domain names composed of information closely matching existing trademarks are authorized by the relevant general licenses for the Iran and Sudan programs”. In Case No. IA-2013-300346-1, OFAC clarified that "other intellectual property" and "other forms of intellectual property" as used in section 560.509 include domain names composed of information that exactly or closely matches existing trademarks in Iran. Here, OFAC goes a step further by explicitly clarifying that “transactions with respect to domain names composed...

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Case No. MUL-314-2

TURBOFAC Commentary (276 words)