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.
[Update/Note - OFAC implemented EO 13902 into the ITSR subsequent to the drafting of the comment below. See 560.211 and comments thereto]
Read in conjunction with LICENSE No. IRAN-EO13902-2025-1370670-1, 2, 3, and comments thereto. This Blocking Pending Investigation Memorandum relates to the vessel that was blocked on April 22, 2025 pursuant to EO 13902 for being “property in which Pearl Petrochemical FZE has an interest” (Pearl was designated on April 22, 2025). See https://ofac.treasury.gov/recent-actions/20250422. This is a notable example of OFAC ensuring that property within the possession or control of a U.S. person (the vessel was in U.S. waters at the time of the BPI Memorandum) stays frozen while OFAC investigates whether its non-U.S. person owner should be designated (where there was no public...