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) Read in conjunction with FAQ # 1204, and compare Global Magnitsky General License 8 (similar GL authorizing transactions involving non-designated entities owned by an individual SDN that would otherwise be blocked by the 50 Percent Rule).
2) For information on the litigation carved out of the GL, see https://www.elitigation.sg/gd/s/2024_SGCAI_5. The litigation involves the “Mandalay Trust” which was established “for the benefit of Mr. Ivanishvili and his family” and “comprised bankable assets and various artworks.” Given that the litigation-related provision is a carveout, rather than a “note,” the implication should be that the trust itself is a blocked entity with respect to which dealings could have otherwise been authorized but for the carveout, but it is not necessarily the case that OFAC made an...