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) Provision unique to the CACR. The typical sanctions regulation defines "U.S. financial institution," distinguishing between branches and subsidiaries, but for the purposes of the CACR, the distinction is not meaningful as both are considered a "Person subject to the jurisdiction of the United States" ("515.329"). Note that while the definition of "financial institution" in the typical sanctions regulation appears broader than "banking institution" for the purpose of the CACR may appear narrower than that of the definition of "financial institution" in the typical modern sanctions program, but it is unlikely that OFAC would interpret it as such.
2) See Case No. CU-2019-361318-1 for OFAC appearing to regard the New York Office of the State Comptroller abandoned funds office as being a “banking institution” for purposes of this provision.