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) See relevant enforcement action: Civil Enforcement Information - American International Group, Inc. (1st action) (2014).
2) Note that, where IEEPA's Berman Amendment for travel is applicable, the provision of travel insurance is permitted as ordinarily incident to the travel itself. With Cuba, though, travel is not permitted at baseline. See comment to JCPOA Implementation FAQ D-7:
"Can U.S. insurers provide travel insurance to individuals traveling to Iran?
Yes, travel insurance continues to be exempt from regulation by OFAC as ordinarily incident to travel. Please see FAQ 104. [01-16-2016]"
3) This FAQ highlights the distinction between transactions ordinarily incident to those that are authorized or statutorily exempt, on the one hand, and transactions ordinarily incident to those that are not actually prohibited in the first place, on the other. 515.421, which can include insurance within its scope, only applies in cases where the related transaction is authorized or statutorily exempt, and most transactions involving only non-U.S. parties are simply not subject to the regulations to begin with.
4) Note that the FAQ addresses the question of whether insurance may be provided to “non-U.S. persons providing goods or services that facilitate travel by third-country nationals from a third country to Cuba.” The FAQ does not address insurance provided to non-U.S. persons in connection with their travel to Cuba, where such travel would, if it were subject to U.S. jurisdiction, be within the scope of one or more of the CACR’s general licenses for travel to Cuba.