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) BACKGROUND
Case No. IA-2018-357507-1 is one of the few illuminating guidance letters on file concerning the application of secondary sanctions and other designation criteria to above-board, standard international trade transactions of a sort described in Introductory Note Common to all Derivative Designation Notices Included in the Research System.
At the time October 16, 2018 request for interpretive guidance by Alitalia, which at the time was the flag carrier and largest airline of Italy, the U.S., on May 8, 2018, had already announced its intention to withdraw from the JCPOA and re-impose certain secondary sanctions provisions that had been waived pursuant to the JCPOA.
More specifically, on May 8, 2018, the U.S. announced that there would be a “90-day wind-down period ending on August 6, 2018” after which a subset of pre-existing...