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) Provision identical to analogue in 20 other sanctions regulations involving the blocking of property (certain abbreviated sets of regulations have omitted the provision).
2) For the only post-2005 enforcement action seemingly related to this provision, see Civil Enforcement Information - Richland Trace Homeowners Association, Inc. (2012)/ Penalty Notice - Richland Trace Homeowners Association, Inc. (2012). There, the operators of a blocked condo applied for and received a license to liquidate the property, but acted outside the scope of it by reimbursing themselves for arrears.
3) See 598.511 for the general license, added on 5-17-2021, for expenses related to the maintenance of blocked tangible property. Prior to that, OFAC appears to have had a policy of licensing payments to U.S. persons by blocked persons for maintenance of tangible property, so long as the funds used for the payments were “fresh funds.” See LICENSE No. FNK-2017-340944-2; Rahn Bahia Mar LLC v. M/V Waku et al (0:17-cv-60447); (0:17-cv-60449) (S.D.F.L. 2017); OFAC Licensing Director's Declaration, and comments thereto. But compare ENF 53208 (Notable Notification of Blocking) (2019).
4) With respect to the licensing policy articulated in subsection (b), see e.g. LICENSE No. VENEZUELA-EO13850-2019-359725-1 and License No. FNK-532a, and comments thereto.