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) Lukoil International GmbH is the primary holding company through which Lukoil holds its non-Russian assets, the acquisition of which by Gunvor SA (Switzerland) was proposed prior to the issuance of this GL and rejected by the USG (see https://www.lukoil.com/PressCenter/Pressreleases/Pressrelease/lukoil-receives-offer-from-gunvor-to-purchase and https://www.reuters.com/business/energy/gunvor-says-withdraws-bid-buy-assets-russian-energy-firm-lukoil-2025-11-06/. While such transaction appears to have been within the scope of paragraph (a) of Russia GL 127 if it had been concluded in prior to the Nov. 21 expiration of that GL, this GL is valid through Dec. 13, 2025, though it comes with two key proviso that “the performance of any such contract is made expressly contingent upon the receipt of separate authorization from the Office of Foreign Assets Control”.
2) The GL also authorizes “all transactions prohibited by E.O. 14024 that are...