OFAC Enforcement - ZAG IP, LLC

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 (527 words)

Notes:

1) This is a relatively rare case of an enforcement action that was based solely on a "dealing in" Iranian-origin goods, where there appears to be no other Iranian person involvement in the underlying transaction. While 560.206 prohibits transactions "related to" a variety of actions that themselves violate other prohibitions of the (e.g. a transaction "related to" an import of Iranian goods to the U.S.), 560.206 also provides a stand-alone prohibition against dealing in Iranian-origin goods, irrespective of who actually has title to them and whether Iran or any Iranian party are actually involved with the transaction.

2) The fact pattern is notable for OFAC going out of its way to highlight that the violation arose from the company being caught in a difficult commercial situation, while at the...

Welcome!

Welcome!

Civil Enforcement Information - ZAG IP, LLC

TURBOFAC Commentary (527 words)