Notable Corresp. w/ the SEC re: Sanctions - - Reynolds American Inc., Correspondence with the SEC Office of Global Security Risk (2006); LICENSE No. IA-7315

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 (291 words)

Notes:

1) Notable illustration of where the "general inventory" or "warehouse rule" is not applicable. Here, a U.S. corporation entered into an agreement with a non-U.S. company pursuant to which the non-U.S. company would distribute U.S.-made cigarettes throughout the world. While all indications are that the sales to Iran would be a comparatively minor portion of the overall sales made pursuant to the agreement, some sales to Iran were nevertheless specifically contemplated, and the non-U.S. party had a Dubai-based distributor in place to re-export a portion of what was manufactured to Iran [1]. This meant that, minor as the overall degree of sales may have been to Iran, the warehouse rule was not available because, in spite of the lack of "predominance" of the dealings between the non-U.S. person and Iran, at least some of the products were "intended specifically" for Iran. That OFAC needed to license...

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Reynolds American Inc., Correspondence with the SEC Office of Global Security Risk (2006); LICENSE No. IA-7315

TURBOFAC Commentary (291 words)