OFAC FAQ (Current) # 867

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.

TURBOFAC Commentary (200 words)

Notes:

1) This is the first FAQ in which OFAC confirms that its generally applicable policy as it relates to secondary sanctions—i.e. of not sanctioning non-U.S. persons for activities in which U.S. persons could engage directly—also applies to the secondary sanctions provisions of the Sec. 7401 et seq. of the FY 2020 (“Caesar Syria Civilian Protection Act of 2019”). Compare FAQ # 545. Refer generally to General Note on "Counterfactual Secondary Sanctions and Derivative Designation Safe Harbors" in Certain OFAC Guidance and FAQs (System Ed. Note)

Otherwise, the FAQ does not provide much in the way of anything that could be characterized as "interpretive guidance."

2) It is not spelled out in the regulations, but OFAC confirms that the CBoS can be involved in the processing of transactions...

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OFAC FAQ (Current) # 867

TURBOFAC Commentary (200 words)