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) Refer to the second-to-last paragraph in the Treasury letter (PDF file contains surrounding letters sent from the Senator).
There is little in the way of statements attributable to OFAC and/or Treasury that speak to the actual purpose of the 50% rule, which makes interpretation of the rule difficult at the margins. If, for example, the purpose of the 50% rule were that 50% ownership acts as a reasonable proxy for control, one might wonder whether a 50% ownership of voting interests triggers the 50% rule (even where there is no majority ownership by total shares). Here, in response to a question from the Senator erroneously presupposing that "U.S. persons are not permitted to do business with individuals or entities 50 percent or more owned or controlled, directly or indirectly, by an SDN," the former Treasury Secretary states...