OFAC Info. for Industry Groups - Notice to Mariners - 2006 Update - A general overview of OFAC for mariners and shippers that was published on January 7, 2006 by the National Geospatial-Intelligence Agency (NGA).

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 (824 words)

Notes:

1) This guidance was removed from OFAC's website in 2018. The principles of generally applicably are still valid today, but note that the sanctions against North Korea referred to are those of the , which with prohibitions as broad as the concerning non-U.S. entities owned or controlled by U.S. persons.

2) References to Cuba are somewhat of date given the amendments to the CACR, in particular 515.550, which modifies the severity of the "180-day rule" for the carriage of certain items. Note however how OFAC highlights the application of 515.207 even in the case of "minor repairs" handled in Cuba. This would apply today as well.

3) OFAC's discussion of the relationship between "U.S. jurisdiction" and vessels is notable,...

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Notice to Mariners - 2006 Update - A general overview of OFAC for mariners and shippers that was published on January 7, 2006 by the National Geospatial-Intelligence Agency (NGA).

TURBOFAC Commentary (824 words)