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) "Government of Venezuela" - Personal and Representative Capacity
Up through the release of these enforcement actions, it was not clear whether OFAC would read EO 13884 so as to prohibit dealings with GoV employees, even low-level ones, acting in their personal capacities, rather than on behalf of the government in the context of any particular transaction involving a U.S. person. The wording of Venezuela General License 34 suggested a likelihood that OFAC would take that position, with a GL that applied to dealings with “[c]urrent employees and contractors of the Government of Venezuela who provide health or education services in Venezuela, including at hospitals, schools, and universities” (suggesting that “current employees” of other types of entities were blocked even when acting in their personal capacities). It is now clear that...