OFAC FAQ (Current) # 398

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.

TURBOFAC Commentary (544 words)

Notes:

1) Concerning the proposition that entities "controlled" by SDNs are not blocked without an affirmative determination, see e.g. OFAC SpaceX Litigation Correspondence (2014) and FAQ # 368. In dealing with such entities, one must avoid "indirect dealings" with SDNs.

2) Apart from the fact that all Cubans are blocked under the (unless unblocked by ), note that entities owned or controlled by the blocked governments of Iran, North Korea and Syria are also blocked by operation of law, i.e. without an affirmative determination. See e.g. Case No. IA-2013-302020-1, analyzing the question of whether an entity is "controlled" by the .

3) FAQ # 398 makes clear that in the blocking context, for which the embedded “service” prohibitions are no less broad than they are in...

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OFAC FAQ (Current) # 398 - 50% Rule

TURBOFAC Commentary (544 words)