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
This guidance letter relates to 515.517 of the CACR, which exists as of 2/2022 just as it did in 1998, and 515.568, which has since been removed from the CACR. See p. 9 of the PDF file for 515.568, as it existed when the guidance letter was issued. The specific licensing policy at the old 515.568, which dealt with “U.S. assets of certain Cuban decedents,” is now covered by the GL (implemented on Sept. 21, 2015) at 515.523 (Transactions incident to the administration of decedents' estates). The relationship between 515.517 and 515.523 is discussed further below.
515.517 provides/provided in relevant part as follows:
(a) Access to any safe deposit box leased to a designated national or containing property in which any designated national has an...