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) This GL is unique to the ITSR, but OFAC seems to be suggesting that to "collect, accept, [or] process student loan payments from persons in Iran or ordinarily resident in Iran" would, without this GL, constitute the "export" of a "financial service" to Iran (560.204). As an implied statement concerning the scope of the broadly applicable "export of services" concept, the statement has cross-programmatic implications.
2) Consult Case No. IA-18450, interpreting this GL. That guidance involves what appears to be a U.S. bank asking if it is permitted to process the loan payments in its capacity as a service agent, rather than an account party. OFAC seems to consider the applicant’s role as permissible as a transaction permitted by 560.516, ordinarily incident to the transaction authorized by 560.551.
3) This GL, on its face, appears to allow for the facilitation of underlying transactions that are not subject to the prohibitions of the ITSR. See General Note and Associated Matrix Pertaining to U.S. Person Engagement in Transactions Incident to Transactions by Foreign Persons (System Ed. Note).