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.
This provision was amended on 12/27/2021 to account for the removal of the appendix I. See FR notice introducing changes at https://home.treasury.gov/system/files/126/20211223_wmd.pdf.
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The WMDTCR are a rare sanctions program insofar as it is a list-based program that provides for the blocking by operation of law (as opposed to via affirmative determination) for entities "controlled" by designated persons. While OFAC does not define "control" in other regulations, this provision suggests that "acting or purporting to act for or on behalf of" a designated person constitutes "control." For practical purposes, however, OFAC has recently articulated that all "indirect" transactions with blocked entities are prohibited, meaning that even where a "control" standard does not apply, dealing with an entity "acting or purporting to act for or on behalf of" a designated person would probably always constituted a prohibited "indirect dealing" [1]. See General Note on "Control" and "Otherwise Controlled" within the Meaning of the Sanctions Regulations (System Ed. Note).
[1] See 2014 Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked.