OFAC Enforcement - Societe Internationale de Telecommunications Aeronautiques SCRL (“SITA”)

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 (3096 words)

Notes:

1) Bases for Legal Liability — 594.201 and 594.204

OFAC cites violations of both 594.201 and 594.204 of the . 594.201 is the basic blocking regulation, and 594.204 is a separate provision that states that "[t]he making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any person whose property and interests in property are blocked pursuant to §594.201." That the substance of 594.204 is a separate 200-level prohibition in the GTSR—rather than, as is more common, something that is incorporated within a subsection of the basic blocking prohibition—is unique to the GTSR. In other words, these activities would have violated any blocking prohibition, since OFAC almost always explicitly considers the substance of 594.204 (contributions or provisions of funds, goods, or services) to be...

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Civil Enforcement Information - Societe Internationale de Telecommunications Aeronautiques SCRL (“SITA”)

TURBOFAC Commentary (3096 words)