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 FAQ clarified that in order to determine sanctions risk under subsection 11(a)(ii) of Executive Order 14024 (as amended), one may need to cross-reference OFAC and State Department press releases to determine what sectors certain designated persons were designated for operating in.
2) FAQ removed from OFAC’s website on 6-12-24 in light of the expansion of the secondary sanctions provision at subsection 11(a)(ii) of Executive Order 14024 to include all persons blocked pursuant to EO 14024, not just those blocked for operating in certain sectors. OFAC noted (see https://ofac.treasury.gov/recent-actions/20240612) that:
[OFAC has updated the secondary sanctions language on its SDN list related to Executive Order 14024 as amended by Executive Order 14114. This language previously read:
"Secondary sanctions risk: this person is designated for operating or having operated in a...