31 CFR § 525.509 - Official business of certain international organizations and entities.

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.

TURBOFAC Commentary (275 words)

Notes:

1) On 12-21-22, this was added to the regulations, along with over 20 other “Official business of certain international organizations and entities” GLs that were implemented in sanctions regulations that did not previously have the GL [1]. Refer to “Treasury Implements Historic Humanitarian Sanctions Exceptions” (Press Release) (https://home.treasury.gov/news/press-releases/jy1175).(“Treasury is issuing these GLs across sanctions programs that did not previously have humanitarian exceptions, implementing a new standardized baseline set of authorizations across OFAC-administered programs.”)

[1] See https://home.treasury.gov/system/files/126/usg_io_official_business_regulations_amendment.pdf

2) See general discussion of the “official business” licenses and exemptions at General Note on Exemptions and General Licenses for the “Official Business” of the U.S. Government (and/or United Nations) and Employees, Contractors, or Grantees Thereof. This provision is standard; there is no reason to believe that it is or will be interpreted differently than its analogues in other sanctions programs, except insofar as (i) the non-UN entities listed in the GL may be program specific, and (ii) there may be a subsection (b) stating that "This section does not authorize funds transfers initiated or processed with knowledge or reason to know that the intended beneficiary of such transfers is a person blocked pursuant to this part, other than for the purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services." This GL does not have that limitation (compare e.g. 536.513), so we assume that there is no limitation on payments to blocked persons in connection with otherwise authorized activities).

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31 CFR § 525.509 - Official business of certain international organizations and entities.

TURBOFAC Commentary (275 words)