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, which could be regarded as a sort of soft safe harbor for diligence purposes, follows the “may reasonably rely…unless…know or have reason to know” formulation found in other OFAC FAQs such as FAQ # 1106 and FAQ # 1044. This appears to be OFAC’s way of saying that due diligence expectations in this particular context would not entail seeking the corroboration of “information provided to [U.S. persons] by their customers in the ordinary course of business,” but if there is something in such information presenting a clear enough red flag to cast doubt on its legitimacy, there would be no space for “reasonable reliance”. See 515.578 and comments thereto for more on the GL referred to here. Compare FAQ # 1176 (issued on the same day).
* For comments on the scope of “communications”-related GLs in general, see section...