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) FAQ # 975 and FAQ # 990 interpret, among others, two otherwise standard "wind down" GLs that do not contain any caveats or limitations on their faces. See Russian Harmful Foreign Activities General License 3 and Russia-related General License 11. In other sanctions programs OFAC has interpreted similarly worded GLs to authorize the unblocking of property with no apparent restrictions. Compare Venezuela General License 11 and Iran General License (No. K), where the wind-down GLs acknowledge that the text virtually identical to that of paragraph (a) here authorizes the unblocking of property.
This notwithstanding, OFAC has, in effect, used the guidance in FAQs 975 and 990 to impose substantial limitations on Russia-related GLs 3 and 11 that are not otherwise evident from the...