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.
Rare Notable "Owned or Controlled" and "Instrumentality" Determinations
1) "Petrojam Limited" (Petrojam) is a Jamaican company that operates Jamaica’s only oil refinery (or at least was as of the date of the issuance of the letter). According to the 2017-2018 publicly available Petrojam annual report, in 2006 there was an "[a]greement signed between the Governments of Jamaica and Venezuela for PDV Caribe to purchase 49% shares in the refinery" (p. 13 of https://www.petrojam.com/wp-content/uploads/2020/12/par_2018.pdf).
This is consistent with the portion of the guidance letter conveying that "Petrojam [was] 49 percent owned by PDV Caribe, a wholly owned subsidiary of PdVSA," and that "the Petroleum Corporation of Jamaica [held] the remaining 51 percent of Petrojam's shares". The Petrojam board of directors comprised six members, with "three directors appointed by Petroleum Corporation of Jamaica and three (3) appointed by PDV Caribe, with three...