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.
(I) Background
The "CBW Act Directive" and the “EO 14024 Directive” prohibit certain U.S. entities from engaging in transactions involving bonds and lending to certain entities related to the Russian government. The two directives overlap to an extent, but do differ in form and scope.
Note at the outset that, up through 2-22-2022, Directive 1 Under Executive Order of April 15, 2021 was in place alongside the CBW Act Directive, and neither impacted the secondary market for Russian government-issued debt. On 2-22-2022, OFAC issued Directive 1A Under Executive Order 14024, which added a secondary market provision to the two pre-existing prohibitions, and...