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) The “Stop Harboring Iranian Petroleum Act” (“SHIP Act”) is likely the most consequential new sanctions statute enacted as part of the 2024 "National Security Supplemental". As detailed in the Iran Secondary Sanctions Comparison Table, there are, as of 5-3-24, many secondary sanctions authorities targeting Iran's energy sector, but all require at least some sort of direct or indirect dealing with Iran or a person subject to some form of sanction. Here, the sanctions apply with respect to certain dealings (transport, refinement, ship-to-ship transfer) of “Iranian crude oil or petroleum products” / “any petroleum product originating from the Islamic Republic of Iran”. In other words, the sanctions apply to dealings in the covered goods, irrespective of whether there is actual Iranian person involvement. Put differently, the secondary sanctions are a secondary sanctions equivalent of 560.206, which prohibits in Iranian origin goods in a...