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) Although not explicitly characterized as such in this action, OFAC considers the actions at issue an "export to Iran" (560.204) because the account holders were an entity and a person "in Iran," meaning that any services provided to them are services exported to a person "in Iran" within the meaning of 560.410. Compare Civil Enforcement Information - Downey Savings and Loan (2006).
If a person is within the U.S. legally, and then becomes "ordinarily resident" in Iran again, provisions of financial services to that person are prohibited unless specifically authorized or exempt from regulation. See Case No. IA-16053 - OFAC Response to Request for interpretive Guidance.
Here, OFAC just says that a person was "in Iran."
In correspondence with the SEC, Keybank further described the facts underlying violation as follows:
In December 2007, KeyBank National Association...