Office of Global Targeting PPT Presentation (Internal)

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 (417 words)

Notes:

1) This presentation, which dates from around mid-2016 (see p. 11), appears to have been internal to OFAC prior to it being released (see p. 24). The presentation contains some notable insights concerning the designation process and its effects. Some of these statements are obvious, but unusual to see in the context of a document prepared by OFAC.

This includes (i) the sources of information portion of pp. 7 and 8, and (ii) the "may conduct outreach to effect a change" statement at p. 9, the (iii) "Additional Effects of Sanctions" slide at p. 17 acknowledging that designations "[m]ake it difficult for targets to continue any modern financial activity, even with foreign banks".

The presentation also provides some notable interpretations of the standard derivative designation criteria.

2) ACTING ON BEHALF OF

Notable for the statement that "'Acting for or on behalf of' can be interpreted to apply in many...

Welcome!

Welcome!

Office of Global Targeting PPT Presentation (Internal)

TURBOFAC Commentary (417 words)