OFAC Regulatory Provisions - 31 CFR § 515.536 - Certain transactions with respect to merchandise affected by 31 CFR § 515.204.

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 (298 words)

Notes:

As discussed in the comments to 515.204, OFAC interprets "made or derived in whole or in part of any article which is the growth, produce or manufacture of Cuba" so as to include even de minimis amounts of Cuban-origin goods or materials (but see Cuban Cigar Update (2004)). OFAC has traditionally been especially sensitive to the issue of indirect support for the Cuban nickel industry See e.g. - ESCO Corporation (2014).

A version of this provision has existed within the for over 50 years, but it is not clear whether any to what extent it has a practical effect. Neither the original issue of the provision, nor any of the FR notices amending it, nor any other currently available guidance explains what it means to be "presumptively subject to §515.204" (e.g., that a...

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31 CFR § 515.536 - Certain transactions with respect to merchandise affected by 31 CFR § 515.204.

TURBOFAC Commentary (298 words)