OFAC Guidance - Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked

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 (499 words)

Notes:

1) Refer generally to the detailed comments to FAQ 398, FAQ 399, FAQ 400, FAQ 401 and FAQ 402, addressing some of the trickiest issues concerning the application and consequences of the 50% rule.

2) See other documents categorized as involving the "50% rule," and comments thereto, for illustrations of the application of the rule and discussing of other discrete issues raised by this guidance.

3) Note the broad statement that "a U.S. person may not procure goods, services, or technology from, or engage in transactions with, a blocked person directly or indirectly (including through a third-party intermediary)." A handful of executive orders specifically prohibited "indirect dealings" in blocked property, while most do not. This guidance clarifies that the prohibition on "indirect dealings" is implicit in all regulations. Note though that the scope of what...

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Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked (2008 and 2014 versions in PDF file)

TURBOFAC Commentary (499 words)