Export Control Reform Act of 2018 (Selected Provisions)

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 (473 words)

Notes:

1) The Export Control Reform Act of 2018 (ECRA) took effect on August 13, 2018. There are three notable aspects of the law that may have an (indirect) effect on the scope and operation of the and -based informational materials exemptions.

2) “Otherwise Controlled for Export”

First, as discussed at length in section 5 of Notes Common to the "Information or informational materials" Definitional Provision, section 1766 of the broader statute that contains the ECRA repeals the Export Administration Act (EAA). The EAA is directly referenced in the IEEPA informational materials exemption as limiting the scope of the exemption (to exclude materials “which are otherwise controlled for export under section 5 of the Export Administration Act of 1979, or section 6...

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Export Control Reform Act of 2018 (Selected Provisions)

TURBOFAC Commentary (473 words)