FAC No. IQ-214841 [Application Included]

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 (476 words)

Notes:

1) This letter illustrates OFAC's practice of disavowing jurisdiction over once-prohibited transactions once the underlying authority for OFAC's jurisdiction has been revoked.

The revocation of an underlying authority will not prevent OFAC from enforcing violations of once-in-force sanctions regulations, but OFAC stops issuing licenses and providing guidance on the interpretation of provisions for which there is no longer a legal basis for OFAC’s jurisdiction.

2) In this case, the applicant requested an interpretation of Iraqi General License - Section 575.533 of the now-removed Iraqi Sanctions Regulations (Part 575). 575.533 authorized, as of May 23, 2003, all transactions that were otherwise prohibited by the Iraqi Sanctions Regulations, with certain exceptions, including transactions prohibited by 13315.

One type of transaction that was authorized by 575.533 was the importation of Iraqi-origin...

Welcome!

Welcome!

FAC No. IQ-214841 [Application Included]

TURBOFAC Commentary (476 words)