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) Russia-related General License 9 and Russia-related General License 10 authorize different securities-related transactions involving the same entities. Both expire on May 25, 2022.
2) See FAQ # 981, FAQ # 990 and FAQ # 974. Unlike the general wind-down GLs that apply to some of these entities, these two GLs authorize "[d]ebits to accounts on the books of a U.S. financial institution of the blocked entities"..."to the extent ordinarily incident and necessary to effect the transactions authorized".
3) Query: what if any transactions involving Sberbank are authorized by this GL that would otherwise be prohibited by the sanctions applicable to Sberbank as of the date of the issuance of the GL? Potential answer: trades involving Sberbank debt or equity, including derivatives thereof, may be within the...