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.
General Note Concerning Unlicensed Litigation Involving Sanctioned Persons or Property; the Question of Whether Judicial Action Constitutes the Unlicensed "Transfer" of Blocked Property (System Ed. Note)
1) BACKGROUND
2) U.S. PERSON LAWYERS REPRESENTING SANCTIONED PERSONS
3.1) UNLICENSED LITIGATION THAT INVOLVES BLOCKED PERSONS OR THEIR PROPERTY – OFAC'S JURISDICTION GENERALLY INTERPRETED TO ONLY COVER “TRANSFERS” (AND ORDERS “EFFECTING” TRANSFERS)
3.2) UNLICENSED LITIGATION INVOLVING WRITS OF ATTACHMENT FOCUSING ON BLOCKED PROPERTY – FROM COMPLAINT TO EXECUTION
3.3) SPECIAL TREATMENT FOR IN REM LITIGATION THAT FOCUSES ON BLOCKED PROPERTY
4) THE TERRORISM RISK INSURANCE ACT (TRIA) EXCEPTION
5) CERTAIN LITIGATION-RELATED ACTIONS THAT DO AND DO NOT CONSTITUTE “TRANSFERS” OF BLOCKED PROPERTY OR THE ISSUANCE OF ORDERS THAT EFFECT TRANSFERS
* In general:
* “Attempts”
* Judicial orders constituting “contingent transfers” are probably not “transfers” or otherwise subject to OFAC’s jurisdiction
* “Negotiations” involving blocked persons and property are usually prohibited,...