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) FAQ amended on 8-21-24 concurrent with Modernizing Treasury’s Office of Foreign Assets Control (Press Release), detailing several modernization efforts, including the updating of a number of general interest FAQs containing dated language. This FAQ was amended to add language clarifying, among other things, how OFAC’s prohibitions apply to non-U.S. persons. The comments below were drafted (not amended) prior to the 8-21-24 amendment.
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1) See General Note on the terms "Exempt," "Authorized," "Licensed," "Prohibited, "Not Prohibited" and "Sanctionable for comment on the use of the term “prohibited” in this context, as compared to the narrower use of the term in, e.g. FAQ # 74.
2) Many transactions "expressly exempt by statute" are recognized by OFAC as exempt, but not in any way discernible from its website, either in guidance or its regulations. See e.g. Case No. IA-2012-299245-1; section 2(I) of the "Ordinarily Incident" System Note.
3) With respect to the "different foreign policy and national security goals" language, refer to Notes Common to "5XX.101" Provisions (Titled "Relation of this part to other laws and regulations") (System Ed. Note).