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) INDIRECT OWNERSHIP / CONTROL AND 515.329
"Person subject to the jurisdiction of the United States" is defined at 515.329(d) to include non-U.S. persons "owned or controlled by persons" incorporated in the U.S. 515.329(d) does not explicitly state that "owned or controlled" includes indirect ownership or control, but as illustrated here, that is the case, as OFAC regards the Chinese entity (ASMP) to be a person subject to U.S. jurisdiction for 515.329(d) purposes because it is owned by a U.S. person through a BVI company.
2) 515.559 AND EXPORTS OF MEDICAL DEVICES FROM THIRD COUNTRIES TO CUBA
515.559 of the CACR provides as follows:
(2) The transaction is for the exportation of medicine or medical supplies from a third country to Cuba, which shall not be restricted:...