OFAC FAQ (Current) # 917

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 (262 words)

Notes:

Designation criteria that refer to persons “operating in” sectors of targeted economies have been interpreted in vastly different ways by OFAC, but the fact that there are no secondary sanctions imposed on Belarus suggests that the “operating in” designation criterion may, as is the case with Venezuela-related EO 13850, be used as a sort of secondary sanctions mechanism. This, however, remains to be seen, and is relatively rare. See General Note on "Sectoral Sanctions" and Determinations Made Pursuant to EOs Providing for the Blocking of Persons Determined to "Operate In" a Certain Sector.

This is a non-standard FAQ. On one hand, the FAQ states the obvious (that designations pursuant to the "operating in" criteria require affirmative determinations apart from the issuance of the ). On the other hand, OFAC states that "[t]he identification...

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OFAC FAQ (Current) # 917 - Belarus EO

TURBOFAC Commentary (262 words)