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) On June 11, 2019, OFAC designated the “Four Seasons Damascus,” a Syrian entity that was evidently managed by the Canadian [1] “Four Seasons Hotels Limited” (“FSHL”) pursuant to a management agreement. According to the guidance letter, FSHL corresponded with OFAC on June 20, 2019 to inform OFAC that FSHL “terminated management of the ‘Four Seasons Damascus’ effective June 19, 2019”. The purpose of this guidance letter appears to be to assuage concerns of any counterparties of FSHL that the designation of Four Seasons Damascus would not impact dealings between FSHL and third parties. OFAC confirms that U.S. persons could deal freely with FSHL, so long as the dealings do not involve any blocked persons. (Query: where would the travel exemption come into play as it relates to an SDN hotel where the blocking occurs pursuant to an