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) LICENSING POLICY
The application (p. 7), guidance letter (p. 1) and license (p. 3), altogether, are most notable for their statements of licensing policy as it relates to certain educational activities by U.S. persons in third countries involving persons in or ordinarily resident in certain sanctioned countries. In the application, TAMU requests authorization (to the extent required) for activities involving Iran, Syria, and then-comprehensively embargoed Sudan. OFAC responds by citing 560.544 of the ITSR with respect to Iran, and determining that nothing beyond that would be specifically licensed. With respect to Syria and Sudan, OFAC issued a specific license to, in effect, put those destinations on equal footing with Iran (i.e. grant with respect to those countries that which is granted in the Iran context by 560.544).
2) THE COMBINED REQUEST FOR...