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).
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Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.
1) The parent company of Stena Bulk is a Swedish Oil Tanker Company, of which the fleet was is partially managed from the U.S.
As noted by Clif Burns at exportlawblog.com at the time of the penalty, these cases likely involved foreign-flagged ship owned by a foreign company that wasn’t making a call at any U.S. ports, but those facts would not render the basic facilitation prohibition of the SSR inapplicable. See "Shallow Water Ships Lead To Deep Fines from OFAC." https://www.exportlawblog.com/archives/454.
2) § 538.407, interpreting the facilitation ban of 538.206, specified that "[t]he prohibition contained in § 538.206 against facilitation by a United States person of the exportation or reexportation of goods, technology, or services between Sudan and any destination (including the United States) bars any unlicensed action by a U.S. person that assists or supports trading activity with Sudan by any person."