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) From a legal basis standpoint, this is a fairly straightforward enforcement action. Non-U.S. person “causes” violations by originating payments in USD where such payments would be prohibited for U.S. persons to process, here because they related to “Iranian-origin goods” within the meaning of 560.306 of the ITSR, thereby implicating section 560.206(a) of the ITSR. Compare e.g. Enforcement Release: SCG Plastics Co., Ltd.. Two notable things about the enforcement release are (i) the penalty amount vis-à-vis the value of the wires processed (unusually high), and (ii) the due diligence expectations conveyed through the Enforcement Release and Settlement Agreement as it relates to “reason to know” in the context of product origin where many of the ordinary diligence boxes can be checked but a combination of unusually low price and other...