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) On 6-5-24, OFAC amended FAQ # 205 (initially issued on 6-22-2012) in a way that amounted to an effective rewriting of the FAQ.
The current version of the FAQ specifies that “U.S. persons may donate funds to and raise funds on behalf of U.S. and third-country NGOs that engage in authorized activities in Syria”. This is consistent with Guidance for the Provision of Humanitarian Assistance to Syria - Q # 2 (see comments).
The FAQ also reiterates certain aspects of the NGO GL at 560.516 without providing interpretive guidance, but note the statement that “U.S. person individuals are not authorized to transfer funds directly to Syria for the purpose of charitable donations, absent a specific license from OFAC.” Does this imply that non-blocked Syrian NGOs are not “nongovernmental organizations” for purposes of 542.516, even thought 542.516(a)...