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) In 2025, Kuncha Kerimova (a non-SDN) sued OFAC in connection with OFAC’s blocking of Heritage Trust (U.S. Treasury Blocks Over Billion in Suleiman Kerimov Trust (Press Release)). According to the complaint, Kuncha Kerimova “is, and was at all times relevant herein, a Russian national. Ms. Kerimova is the Grantor to the Heritage Trust.” Kuncha Kerimova is the mother of the SDN Suleiman Kerimov. In 2026, the lawsuit was stayed pending OFAC’s reconsideration of the blocking action. In this joint status report, the DOJ (speaking for OFAC) and plaintiffs counsel state as follows:
“Finally, to support the [reconsideration] petition and application [for the decanting of the Heritage Trust.], Plaintiff intends to seek information in the possession of third parties, including parties located in the United States. Under the...