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) This letter addresses a request from a Chinese entity that had a wire transfer blocked due to there being an interest of Bank of Khartoum (a Government of Sudan entity located in Sudan). OFAC de-listed Bank of Khartoum on April 28, 2011 (https://www.federalregister.gov/documents/2011/06/09/2011-14287/unblocking-of-blocked-persons-pursuant-to-executive-order-13067-and-executive-order-13412 / https://www.wsj.com/articles/BL-CCB-4339) (apparently due to severance of Government of Sudan ownership) but thereafter maintained the comprehensive embargo on Sudan for several years, where the provision of all services to Sudan was prohibited. The guidance letter is notable insofar as it implies that dealing in funds in which a Sudanese bank has an interest, i.e. by returning them to the Chinese entity, does not necessarily constitute a transaction that was prohibited under the otherwise very broad non-blocking provisions of the then-in-force SSR (for example provision of a...