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.
1) This advisory was initially published on November 20, 2018; updated on March 25, 2019 and September 11, 2024. See the native PDF for all three versions, along with a redline comparing the 2019 and 2024 versions. The 2024 updates are mostly time-based “cleanup” actions (e.g. adding references to Russia, adding vessels to the annex, adding a reference to the Caesar Act, and removing a reference to the NDAA 2012 “significant reduction exception”). The advisory “replaces the one previously issued in coordination with the U.S. Department of State and the U.S. Coast Guard on March 25, 2019”.
2) One notable change in the 2024 version is the addition of the following statement:
“[a]s described above, non-U.S. persons, including non-U.S. financial institutions, may face secondary sanctions risk for engaging in activities that are in violation of the CAESAR Act...