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.
The way that "indirect ownership interests" of blocked persons are calculated for the purposes of OFAC's "50% rule" is extremely idiosyncratic. OFAC has provided useful guidance for "indirect ownership" calculations in FAQ # 401, a part of which is reproduced below. For context, we first draw attention to the particular way in which OFAC's notion of "indirect ownership" differs from the concept in other contexts.
Using the term "Covered Person" to refer to SDNs and "Subject Entity" to refer to entities to which one is applying the 50% rule in order to see if the entity is blocked, if (blocked) Covered Person A owns 10% of Subject Entity B, and Subject Entity B owns 80% of Subject Entity C, what is the indirect ownership interest held...