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) Compare FAQ # 1005, which was amended concurrent with the initial issuance of this FAQ to "clarify" that secondary market trading in pre-existing Russian securities was prohibited by the new investment ban.
2) The relationship between this FAQ and the "maintenance" exclusion to the new investment prohibition is uncertain, and involves a number of important interpretive questions.
Does the exercise of pre-existing call options, rights under warrants, etc., constitute “maintenance,” to the extent that it otherwise constitutes “investment”? What about the restructuring of debt in general, including when a debtor gets new assets in return for debt? Does it matter if the debt restructured is a convertible note that contemplates the conversion of the debt to equity?
The issuance of Russia-related General License 45 suggests that much of this may be within the scope of the new...