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) ACTUAL AND CONSTRUCTIVE NOTICE FOR “EFFECTIVE DATE” PURPOSES
The preface to this data specifications document, with language that overlaps with the prefaces to the actual text versions of the full SDN list (See e.g. https://www.treasury.gov/ofac/downloads/sdnlist.txt and lists of changes to the SDN list (https://www.treasury.gov/ofac/downloads/sdnnew19.txt), specify two important things that are not otherwise contained in OFAC's regulations.
First, OFAC characterizes the SDN list as a "reference tool providing actual notice of actions by OFAC with respect to Specially Designated Nationals and other entities whose property is blocked." OFAC says that the changes to the SDN list may "appear here prior to their publication in the Federal Register," but in practice this is almost always the case. OFAC appears to characterize electronic changes to the SDN list as providing "actual notice" of the changes, whether or...