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) BACKGROUND
This letter (see p. 92, native PDF) was issued at a time when the U.S. was in the midst of a significant expansion of its secondary sanctions authorities vis-à-vis Iran, and in connection with a bank that was suspected by OFAC of sanctions evasion. Halkbank ended up being criminally prosecuted for sanctions violations, some of which took place during the period at issue here. (See U.S. v. Turkiye Halk Bankasi A.S.)). The Halkbank case is the first (and as of this writing only) criminal prosecution against a significant non-U.S. person bank for sanctions violations that was not settled pursuant to a deferred or non-prosecution agreement. The criminal case is ongoing as of the date of the last update of this page (12-8-2021). See docket at https://www.courtlistener.com/docket/16341671/united-states-v-zarrab/. In addition to the bank itself, the individuals addressed in these...