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) See PDF for initial voluntary disclosure and final report. From a legal basis standpoint, the implicit determination that the facts described amounted to one or more violations is relatively straightforward. A U.S. person (Expedia) accepted Cuba-related travel reservations “arranged by third party partners” where there was no authorization to do so. According to the disclosure (p. 7) a software error resulted in 70 prohibited bookings, with 62 not resulting in travel because they were canceled by Expedia, who refunded all commissions received from third parties in connection with the prohibited bookings.
2) From a policy standpoint, cancelation of the bookings and refunds of commissions appears to be a good result since it minimized harm to sanctions objectives vis-à-vis a result where the reservations were not canceled, but query whether each of those cancelations and refunds were, in addition to the prior...