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).
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Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.
1) There have been several enforcement actions arising from exports to oil rigs in Iranian waters [1], and a CACR-related one based on the shipment of products outside of Cuban waters but inside its Exclusive Economic Zone [2]. In Stanley Drilling Equipment & Supply, Inc., OFAC imputed a "reason to know" about the destination onto the exporter because information about the rig was publicly available.
Note that Iran's exclusive economic zone includes areas around the Persian Gulf that may be used in ordinary shipping activity not related to Iran. §560.306 specifies that "Goods transported on a vessel or aircraft, as well as the vessel or aircraft itself, that passed though Iranian territorial waters or stopped at a port or place in Iran en route to a destination outside of Iran and that have not otherwise come into contact with Iran" are not "Iranian origin and Iranian-origin goods" "provided that such goods were not grown, produced, manufactured, extracted, or processed in Iran."
[1] See e.g. McGriff, Seibels & Williams of Texas, Inc (2011); Stanley Drilling Equipment & Supply, Inc. (2013); Indam International, Inc. (2014), and COSL Singapore Ltd (2012).
[2] CGG Services S.A (2016).
2) See Case No. IA-12784, suggesting an overflight over Iran is not an "exportation" of an aircraft "to Iran", notwithstanding that Iranian airspace is at least arguably "territory...over which the Government of Iran claims sovereignty."