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) See NGO-Humanitarian Guidance, where OFAC makes the same statement concerning dealings with entities controlled by SDNs but not otherwise blocked.
2) See FAQ 398 and comment thereto for clarification of this concept in an explicitly cross-programmatic manner. OFAC interprets all regulations and executive orders to which the 50% rule applies such that blocking by operation of law is done only with respect to ownership interests, whereas either ownership or control can result in OFAC making an affirmative determination to designate an entity. See also OFAC SpaceX Litigation Correspondence (2014); General Note on the Distinction Between Blocked Person "Control" Over Property and "Control" over the Assets of a Company Controlled by a Blocked Person.
3) OFAC uses the language "profiting from" to describe what it apparently would consider to be an "indirect" dealing with an...