Sanctions - U.S. v. Turkiye Halk Bankasi A.S.

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 (1097 words)

Notes:

*Jul. 2020 Update: The 2nd Circuit court of appeals rule, in U.S. v. Atilla (2nd Cir. 2020), that the one cannot violate the by "evading" or "avoiding" a secondary sanctions provision. Instead, the "evasion" and "avoidance" language extends only to conduct that is actually "prohibited," i.e. itself unlawful, rather than merely "sanctionable." This accords with the views expressed below. The court also held, notably, that in the prohibition on “evading” or “avoiding” sanctions laws needn’t be interpreted in a manner that treats “evading” and “avoiding” as separate prohibitions with differing scopes.

This criminal indictment was issued in connection with the same activities underlying the criminal cases U.S. v. Zarrab and United States v. Atilla. See the following Research System documents, which detail those activities and the way that the trial court handling the...

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U.S. v. Turkiye Halk Bankasi A.S.

TURBOFAC Commentary (1097 words)