Enforcement Release: Rice Lake Weighing Systems

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 (123 words)

Notes:

1) Compare e.g. PACCAR Inc., and comments thereto (EU subsidiary of U.S. company exported items to third countries “it knew or had reason to know were ultimately intended for buyers in Iran”).

2) OFAC notably, and possibly for the first time, characterizes as “reckless disregard for U.S. sanctions requirements” a situation where the entity as issue “mistakenly believed that [its activities] were permissible”.

3) While this enforcement release does not break any legal ground, it is notable for the compliance considerations and statements concerning expectations on U.S. parents of foreign subsidiaries. From a diligence/compliance program expectations perspective, OFAC clarifies its expectations that U.S. parent companies of foreign subsidiaries are expected to ensure that their subsidiaries understand the contours of OFAC’s prohibitions.

Welcome!

Welcome!

Enforcement Release: Rice Lake Weighing Systems

TURBOFAC Commentary (123 words)