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) BACKGROUND
This guidance letter is notable for being the only scenario in the Research System in which OFAC directly addresses the sanctions implications of software of U.S. origin that is known to be “published” for EAR purposes. The guidance is also notable for its unusual application of the “inventory rule” in the software context.
2) APPLICATION OF THE GENERAL INVENTORY RULE AND “REASON TO KNOW” IN THE EXPORTATION OF SOFTWARE CONTEXT
OFAC addresses the potential indirect exportation of certain published software to embargoed destinations through “international organizations”. It is highly likely that the “international organizations” at issue were international organizations of which Cuba, Iran or Sudan were actually members, hence the heightened re-export risk once the international organizations were provided with the software.
The NNSA noted that it was “preparing...