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) GL discussed at FAQ # 794 and Cuba FAQ # 795.
2) On its face, this GL appears conducive to particularly broad interpretation (especially the open-ended reference to "awards" "related to" "scientific research"), but OFAC has not provided further useful guidance, and GLs in other sanctions programs are too comparatively narrow to be of interpretive use.
3) A law firm reports that:
OFAC has issued informal guidance that states that such grants, scholarships or awards may be provided to a “Cuban state-owned entity or any other entity in which Cuba or a Cuban national otherwise has an interest” provided they are used for educational activities, humanitarian projects, scientific research or religious activities. However, the federal government continues to remain statutorily prohibited from providing grants to the Cuban government.
See https://www.akingump.com/en/experience/practices/international-trade/ag-trade-law/new-round-of-cuba-sanctions-changes-expand-opportunities-for-1.html
4) See notable guidance letters at Case No. CU-2015-319798-1 and Case No. CU-2016-325292-1.
5) See notable guidance letter at Case No. CU-2019-359325-1 (U.S. medical-related professional association can allow Cubans to participate in their "fellowships" (through the provision of grants/awards/scholarships). These need not be provided by degree-granting educational institutions.