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.
Provision amended effective 5-29-24 to add “§ 515.584(d) relating to funds transfers” to Note 1. 515.584(d) is the “U-turn” authorization allowing U.S. financial institutions to process otherwise prohibited Cuba-related transactions that originate and terminate outside of the U.S. The amended note helpfully clarifies that a U.S. intermediary bank processing transaction involving a person on the Cuba Restricted List does not violate 515.209. 515.209, by its terms, applies to a person that is either the “originator on a transfer of funds whose ultimate beneficiary is…on the…Cuba Restricted List…or as the ultimate beneficiary on a transfer of funds whose originator is an entity or subentity on the Cuba Restricted List.” The comments below the asterisks have not yet been amended in light of the 5-29-24 CACR amendments.
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1) 515.209 is unique among sanctions provisions administered by OFAC insofar...