Iran General License GG, "Authorizing the Wind Down of Transactions Involving Karnkakis and Karnakis"

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.

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TURBOFAC Commentary (206 words)

Notes:

1) Paragraph (a) is a standard wind-down general license, authorizing the processing of underlying transactions that may not involve U.S. persons (see e.g., FAQ 807), but not including authorizations for the "maintenance" of activities.

2) With respect to the scope of the typical "wind-down" , consult the relevant portions of Examples of Transactions Deemed to be, and not to be, Within the Scope of the Standard "Wind-down" and "Maintenance" GLs.

3) Paragraph (b) is a highly unusual authorization. The authorization is for “all transactions involving individuals blocked pursuant to the and acting solely in their official capacity as officers, employees, or authorized representatives of the Karnakis and Karnakis Entities, that are ordinarily incident and necessary to effectuate transactions...

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Iran General License GG, "Authorizing the Wind Down of Transactions Involving Karnkakis and Karnakis"

TURBOFAC Commentary (206 words)