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) Compare Case No. CU-2016-337943-1 and Case No. CU-2016-334368-1, which are other guidance letters citing the GL (515.534) authorizing the negotiation of, and entry into, contingent contracts, and travel to Cuba for the purposes of the same.
2) This case and Case No. CU-2016-337943-1 are similar in that they both involve U.S. person providers of information-related services in the travel industry, and OFAC says “Note that the general licenses at sections 515.534 and 515.564 exclude direct financial transactions prohibited at section 515.209. [] The potential business subject to these negotiations may also be prohibited by this provision.” This appears aimed at conveying that while the general licenses for negotiation and negotiation-related travel do not themselves authorize transactions otherwise prohibited by 515.209, the negotiation of potential future transactions prohibited by 515.209 are authorized by...