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.
*The version of 542.516 in force as of the time of the issuance of the FAQ can be found at https://www.govinfo.gov/content/pkg/CFR-2020-title31-vol3/xml/CFR-2020-title31-vol3-part542.xml#seqnum542.516. Note that the below was drafted prior to the November, 2021 revisions to 541.516.
Refer generally to General Note on "Counterfactual Secondary Sanctions and Derivative Designation Safe Harbors" in Certain OFAC Guidance and FAQs (System Ed. Note).
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1) THE RELATIONSHIP BETWEEN 542.516 AND THE HUMANITARIAN WAIVER AT SEC. 7432(c) OF THE CAESAR ACT
Read in conjunction with FAQ # 867. Polymedics LLC and Letia Company are two entities that were placed on the SDN list on 12-23-2020. The activities in which those entities are engaged presumably relate in some way to humanitarian-related transactions, otherwise OFAC would not have singled them out in connection with the discussion of 542.516 and humanitarian-related...