OFAC - [WMDPSR / ITSR] - General License No. 2 - authorizing certain transactions related to the arrest, detention, and judicial sale of the MV Dandle and the MV Decretive, which are two vessels on OFAC’s Specially Designated Nationals and Blocked Persons list. These vessels are currently under arrest in Malta and Hong Kong, respectively.

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.

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TURBOFAC Commentary (1439 words)

Notes:

1) NOTE COMMON TO [/ITSR] GLs 1-3, 5-9

1a) BACKGROUND

From 2011 through 2014, OFAC issued eight licenses of virtually identical substance for transactions pertaining to the purchase and potential purchase of various vessels detained at third country ports. All of the licenses have either been revoked, or were otherwise permitted allowed to expire without renewal. All of the vessels were, at the time the licenses were issued, SDN-listed entities themselves, blocked pursuant to the WMDPSR in all cases, and in some cases, as discussed further below, blocked pursuant to the as well.

1b) SCOPE OF LICENSED/PROHIBITED ACTIVITY

The nature and scope of the licenses is notable for a few reasons....

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TURBOFAC Commentary (1439 words)