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.
An entity owned by multiple blocked persons (hereinafter the “Subject Entity”) is a person blocked pursuant to the 50% rule, even if the ownership is by persons blocked pursuant to unrelated sanctioned programs. The open question addressed in this comment concerns the determination of the programs pursuant to which the Subject Entity is blocked, which would normally have an impact on the exemptions and licenses for which the Subject Entity is eligible.
This represents a somewhat gray area of the law insofar as we are unaware of OFAC directly addressing the central question with definitive guidance. That question is under what circumstances will minority ownership by a person blocked pursuant to a certain sanctions program result in a Subject Entity in which it has a minority stake being considered blocked pursuant to the same sanctions programs as the minority owner.
First, consider the text of the...