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) SUBSTANCE
From a substantive standpoint, the Mashreqbank FOV presents facts and a theory of legal liability that are fairly standard for enforcement actions of the genre. A non-U.S. person bank routed USD-denominated payments through the U.S. financial system—through one of its own NY-based branches and other NY-based correspondent banks—that U.S. persons themselves were prohibited from processing due to the then-in-force Sudan embargo. In so doing, the non-U.S. person bank “caused” the U.S. person banks to violate the SSR (at a minimum the service export prohibition of 538.205). Factual detail is relayed in the OFAC-issued enforcement release, as well as the agreements with other agencies referred to in the OFAC release (see Order to Cease and Desist (Federal Reserve) - Mashreqbank PSC and...