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 is one of the few Iranian vessel-related enforcement actions to be issued prior to the designation of the IRISL as a blocked NPWMD, such that the company and its vessels were considered blocked property in which no U.S. person may deal.
Here, the basis for the penalty appears to be the simple "transaction" related to "services" of "Iranian origin." This fact pattern may have been classified a violation of 560.206 (Prohibited trade-related transactions with Iran), rather than an "import of services" (560.201), possibly because the goods did not travel to or from the U.S., and the service was not for the benefit of a U.S. person.
2) There are two notable things about this. First, it means that the notion of an "import of services" within the meaning of 560.201 is effectively made redundant by 560.206, because it is hard to imagine a situation in which an "import" of Iranian origin services did not also amount to an a "transaction or dealing in or related to...Goods or services of Iranian origin" within the meaning of 560.206. In any event, recent enforcement actions suggest that because the use of the services of a U.S. person could make the transaction an "import of services" irrespective of the starting and ending points of the vessels.