Notable "Derivative" Designations - PB Tankers S.P.A. (Italy)

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 (1233 words)

Notes:

1) For the criteria we use to determine what designation notices to include in the Research System, see Introductory Note Common to all Derivative Designation Notices Included in the Research System.

2) This is a rare, notable designation notice for the following reasons.

First, it is one of the few that sanction persons for engaging in international trade transactions that meet the criteria detailed in the "Introductory Note" referenced above [1]. Those criteria, when met, indicate that derivative designation authorities are being used as "quasi secondary sanctions," even where, as here, there were theoretically no "secondary sanctions" on Venezuela at the time of the designation.

Second, the designation is a rare use of a primary sanctions designation authority to designate a person for "operating in" a given sector of a targeted economy as a result of an international trade transaction...

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Notable "Derivative" Designations - PB Tankers S.P.A. (Italy)

TURBOFAC Commentary (1233 words)