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) BACKGROUND
While paragraph 26 is a "kitchen sink" description of the sanctions violations at issue ("violated, attempted to violate, and caused a violation of..."), a viable legal basis for the allegations is relatively straightforward with Bonham Carter--as a front-man for Deripaska--having "caused" U.S. persons to indirectly provide funds and services for the benefit of Deripaska. Compare Settlement Agreement (OFAC) - UniCredit Bank AG (non-U.S. bank causing the exportation of services through a front company to a blocked person).
Two factual bases for violations are alleged. One is the making of payments to a U.S. bank for the upkeep of Deripaska's U.S.-based properties. (Note that Gracetown Inc. was sent a blocking notice on the day that Deripaska was blocked (see ENF 51231 (1) (Notable Notification of Third Party Blocking)), so it is somewhat strange that Deripaska and...