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.
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0) On 1-17-23, OFAC amended FAQ # 1055, which governs the relationship between the "new investment" prohibition and third-country companies, like VEON, that derive significant revenue attributable to Russia. The comments below the asterisks were drafted in connection with the release of "Russia-related General License 54", which was issued when the original version of FAQ # 1055 was still in force. On 1-17-23, OFAC amended this GL to add the "VEON Holdings B.V." in what is now "debt or equity securities of VEON Ltd. or VEON Holdings B.V." The comments below have not been amended in light of the issuance of the amended FAQ # 1055 and Russia-related General License 54A.
With respect to the amendment to the GL, it appears that for the purposes of the prohibition on “purchasing a debt…interest in, entities located outside of the Russian Federation” (new FAQ...