If this is your first time here, take a look at our FAQ page and get a sense of our unique scope of coverage by perusing the Research System interface.
Also, please note that this website is not yet fully functional on mobile browsers. We recommend adjusting your mobile browser settings to view the site in Desktop Mode.
If this is your first time here, take a look at our FAQ page and get a sense of our unique scope of coverage by perusing the Research System interface.
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) It is notable that OFAC does not characterize the violations as an export of financial services "to Iran" as a result of the referee being ordinarily resident in Iran.
Instead, OFAC seems to consider the payments to violate 560.206 and 560.208 because they were facilitative or and "related to" "Iranian origin" services, i.e. those of the referee that was ordinarily resident in Iran. These services are of "Iranian origin" even if performed in a third country, as was probably the case here.
560.306 specifies that "Services performed outside Iran by a citizen, national or permanent resident of Iran who is ordinarily resident in Iran, or by an entity organized under the laws of Iran."
2) This activity would not be authorized by Iran General License (No. F).