Case No. SY-2014-310676-1

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 (181 words)

Notes:

1) Compare Case No. SY-2017-339809-1 and Case No. SY-2017-348601-1 (similar).

2) The new standard medical devices authorizes the exportation of "agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices" (see e.g. 579.512). "Medical devices" and "components" thereof are different things.

542.525 authorizes the exportation of "non-U.S.-origin food, medicine, and medical devices that would be designated as 99 under the Export Administration Regulations…if it were subject to the EAR". 542.525 does not explicitly include “components” or “accessories” of medical devices.

The applicant seeks to export "a TRUEresult Blood Glucose Monitoring System and TRUEresult twist Blood Glucose Monitoring System components and accessories to Syria," and OFAC appears to accept the possibility that the proposed...

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Case No. SY-2014-310676-1

TURBOFAC Commentary (181 words)