OFAC “Derivative Designation” Notice - Treasury Targets Iran’s Billion Dollar Metals Industry and Senior Regime Officials

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 (860 words)

Notes:

1) For the criteria we use to determine what designation notices to include in the Research System, see Introductory Note Common to all Derivative Designation Notices Included in the Research System.

2) This designation notice includes some designations that are of a "pure secondary sanctions" nature, meaning that they were made in response to international trade transactions that were not alleged to have been deceptive, contrary to international law, or illegal in any country having jurisdiction over the transactions.

*Pamchel Trading Beijing Co. Ltd. – The entity was designated for "having knowingly engaged, on or after the date of the E.O. 13871, in a significant transaction for the purchase, acquisition, sale, transport, or marketing of iron, iron products, aluminum, aluminum products, steel, steel products, copper, or copper products from Iran, as well as for having materially assisted, sponsored, or provided...

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Notable "Derivative" Designations - Treasury Targets Iran’s Billion Dollar Metals Industry and Senior Regime Officials

TURBOFAC Commentary (860 words)