OFAC FAQ (Current) # 402

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 (2554 words)

Notes:

[2026-04-04 update - read in light of OFAC's 2026 Sham Transactions Guidance. The below has not yet been updated to reflect the issuance of the Sham Transactions Guidance].

1) What OFAC describes here is a special circumstance, as it relates to the unblocking of property, whereby a person is unblocked by "operation of law" but his property remains blocked in the absence of a license from OFAC. This FAQ is particularly important as there is, arguably, nothing in any of the regulations that tends toward the conclusions offered, and there is no other discussion of these issues on OFAC's website. In fact, as discussed below, OFAC’s analysis here is inconsistent with most regulations in at least one respect.

Most notably, there is nothing in the regulations that makes it evident that i) a person "blocked by operation of law" becomes "unblocked by operation...

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OFAC FAQ (Current) # 402 - 50% Rule

TURBOFAC Commentary (2554 words)