Case No. SY-2016-329055-1

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 (252 words)

Notes:

1) 542.510 of the authorizes “[t]he exportation…from the United States or by a U.S. person, wherever located, to Syria…of services that are ordinarily incident to the exportation or reexportation of items to Syria…provided that the exportation or reexportation of such items to Syria is licensed or otherwise authorized by the Department of Commerce.” Separately, 542.404 of the SySR authorizes any “transaction ordinarily incident to a licensed transaction and necessary to give effect thereto”. This guidance letter is notable as a rare example of OFAC acknowledging that where (as here) a authorizes all transactions that are “ordinarily incident” to a given type of a transaction, the standard “ordinarily incident” interpretative provision (here 542.404) still applies. In other words, the “ordinarily incident” language does not occupy the field where it appears...

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Case No. SY-2016-329055-1

TURBOFAC Commentary (252 words)