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) This case demonstrates the breadth of 560.206 as a "catch-all" capable of encompassing transactions that arguably do not fall within the scope of any of the ITSR's other broad prohibitions. (Compare General Re (2011)). It is not necessarily the case that the only viable theory of liability here was 560.206, but given the scarcity of cases where only this provision is cited, it seems possible that this is the case.
The facts here are somewhat sketchy. We do not know, for example, whether the payment was being made on behalf of a person ordinarily resident in Iran, if an Iranian shipping company is involved, or if the goods are of Iranian origin. If so, the theory of liability is relatively straightforward (either 560.204 of 560.206).
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