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.
1) The "substantially transformed" test acts as a "safe harbor" with respect to both the 560.201 import ban and the 560.206 prohibition on transactions "related to" "Iranian-origin goods." Note that this "substantial transformation" safe harbor is not an interpretation of what an "import ban" covers by default, but rather a feature of the ITSR (and SySR), presumably for policy reasons related to the impracticability of ensuring that no petroleum or petrochemical products contained any Iranian-origin raw materials (cf H. Rept. 113-177 - Nuclear Iran Prevention Act of 2013—passed House, stalled in Senate—which called for a study on the feasibility of repealing this provision as it relates to oil). OFAC's default position seems to be that, without a "substantial transformation" interpretive provision, an import ban prohibits the...