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 # 1059 (and see comments thereto), which is the “benefit of the services is ultimately received” / “indirect” FAQ in the context of the 5-8-22 Professional Services Determination, 5-19-23 Architecture and Engineering Services Determination and 9-15-22 Quantum Computing Services Determination. This FAQ provides examples of an “indirect” provision of services that are tech-specific, but the two FAQs appear to follow the same logic. Accordingly, this FAQ has some relevance for each of the other three service prohibitions discussed in FAQ # 1059.
2) As with FAQ # 1059, the two “not prohibited” examples provided are examples where the third country entity “has an office and employees in the third country and conducts business in this third country, and the services will not be reexported to the Russian parent company.” This is evidently enough to establish...