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. IA-2018-XXXXX-X, which is substantially the same guidance letter, but here the subject is “a free app that provides a platform for aggregated sales of goods and commodities on various social network platforms,” which is decidedly less clear a fit for a “personal communications” GL than is the “messenger app” described in the other guidance letter.
Here, with the reference to "paragraph (a)(3) of GL D-1 and item 8 of the Annex to GL D-1," OFAC appears to take the view that Shopgram would qualify for the GL, but for the fact that it is an app of Iranian-origin. For more on the scope of these GLs as applied to software, see General Note on Prohibitions, Licenses and Exemptions as Applied to Social Media and Other Communications-Related Internet...