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.
[NOTE - This GL appears to have effectively been extended, at least to some degree, through Jan. 31, 2023, by License No. RUSSIA-EO14024-2022-983909-1]
1) Read together, FAQ 1071 and GL 45 make clear that OFAC regards the entry into derivatives contracts linked to debt of Russian issuers to be prohibited "new investment". In light of the limitation of the scope of GL 45 to "financial contracts or other agreements that were entered into on or before June 6, 2022," OFAC evidently takes the position that it was only on June 6th that OFAC provided fair notice as to its interpretation of the new investment prohibition as covering secondary market trading in Russian issuer debt. See FAQ # 1054. OFAC would evidently say that, while no June 6th guidance directly addressed derivatives, OFACs guidance was clear enough that...