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.
On 10-18-2023, OFAC issued broadened versions of Venezuela GL 3 and Venezuela GL 9, amended FAQ 661 and FAQ 662 accordingly. One impact of these changes, as described in this FAQ, is to allow “U.S. persons [to] purchase bonds issued by the Government of Venezuela or Petróleos de Venezuela, S.A. (PdVSA) prior to August 25, 2017 on the secondary market”. In October 18, 2023 Venezuela Looseleaf FAQ - # 1, OFAC describes the GL 3 and 9 changes such that the changes have the effect of “removing the secondary market trading bans on purchases of certain Venezuelan sovereign bonds and pre-2017 bonds or equity issued by Petróleos de Venezuela S.A. (PdVSA).”
In both of the GLs, there were, prior to 10-18-2023, two related but distinct restrictions on the otherwise broad authorization for...