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) With the exception of the ITSR, FNKSR and FTOSR, all sanctions programs involving the blocking of persons have a general license either for the provision of emergency medical services, or otherwise for the provision of emergency medical services with the proviso that payments must be specifically licensed. In 2018, OFAC amended the Congo version of the provision to authorize both payments and the provision of the services, and all of the other six programs generally licensing both services and payments are the provisions most recently issued and/or amended. This suggests that, for all programs in which payments need to be specifically licensed, licenses for payments would be granted as a matter of course,
Note that certain of these provisions allow for the receipt of emergency medical services, in addition to the provision of such services. As of 8/2019, the “provision and receipt” language is used in all of the seven most recently issued and/or amended GLs, suggesting that “provision and receipt” reflects OFAC’s default licensing policy. While it is virtually unfathomable that OFAC would initiate an enforcement action based on the receipt of non-scheduled emergency medical services, it should be noted that OFAC would presumably acknowledge that the receipt of such services is exempt from regulation where the IEEPA-based travel exemption applies. For U.S. persons travelling to Iran, Syria or Crimea, for example, such services are quite obviously within the scope of the travel exemption, as are, presumably, certain scheduled medical services ordinarily incident to travel. This provision, as it appears in virtually all sanctions programs involving blocking, is aimed at clarifying what may and may not be done with respect to blocked persons only, and should not be read as implying anything about the scope of the travel exemption.
2) Modern versions of this GL specify that it applies to "any further Executive orders relating to the national emergency" underlying the set of sanctions regulations in which the GL appears. This is notable as it is not the default for EOs unincorporated in sanctions regulations. See General Note on the Relationship Between Executive Orders, General Licenses and Sanctions Regulations Issued Pursuant to a Common National Emergency (System Ed. Note).