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) While the term “information technology (IT) consultancy and design services” is not given a definition in OFAC’s FAQs, this FAQ provides examples of activities that fall within the scope of the term (which is unique to 6-12-24 Tech Services Determination). Of particular note, OFAC specifies that “the retail sale of off-the-shelf software” is not considered “information technology (IT) consultancy and design services,” and this also appears to fall outside the scope of the other portion of the 6-12-24 Tech Services Determination (see FAQ # 1186 and FAQ # 1187).
2) This FAQ addresses situations in which “services were provided to a company located in the Russian Federation that is not owned or controlled directly or indirectly by a U.S. person (Russian company)”. FAQ # 1188 addresses “providing services to persons located outside of the Russian Federation that...