Civil Enforcement Information - Epsilon Electronics Inc. (1 of 2

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 (682 words)

Notes:

1) This is one of only two enforcement actions (issued from 2006 through 12/2020) to be challenged in court. See also Civil Enforcement Information - ExxonMobil Corporation. The challenge resulted in Epsilon Electronics, Inc. v. U.S. Dep't of the Treasury, 857 F.3d 913 (D.C. Cir. 2017).

2) The D.C. Circuit Court of Appeals ruled that:

i) a product need not actually arrive in Iran in order for an exporter otherwise knowing or having reason to know of its ultimate destination to violate 560.204.

ii) Penalty partially reversed, however, because for some shipments OFAC was found to have not adequately explained why it found Epsilon to have known or had a reason to know of the likelihood of transshipment to Iran. In particular, there was evidence suggesting that the...

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Civil Enforcement Information - Epsilon Electronics Inc. (1 of 2 - 2014)

TURBOFAC Commentary (682 words)