Notable Corresp. w/ the SEC re: Sanctions - Overseas Shipholding Group, Inc., Various Correspondence with the SEC (2006-2015)

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.

TURBOFAC Commentary (2282 words)

Notes:

1) THE LIMITATIONS OF THE PROHIBITIONS CONCERNING INDIRECT EXPORTS

Correspondence and disclosures in annual filings (links to each in main document text) are all related to a single, ongoing, widely publicized set of issues concerning the calling at Iranian ports by vessels indirectly owned by the U.S.-person filer.

The case illustrates a rare example of a company appearing to manage to stay on the right side of 560.204 (exports of services), 560.206 (dealings “related to” exports to Iran) and 560.208 (facilitation) where it may appear at first blush that the activity reported was prohibited by the , and where the company has clearly taken pains to organize its affairs around the broad reach of the ITSR.

Here, the U.S.-person company had vessels that it indirectly owned through a non-U.S. person...

Welcome!

Welcome!

Overseas Shipholding Group, Inc., Various Correspondence with the SEC (2006-2015)

TURBOFAC Commentary (2282 words)