Determination Pursuant to Section 1(a)(i) of Executive Order 14068 (Effective June 28, 2022)

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 (147 words)

Notes:

1) This is the first "determination" made pursuant to the broad import ban contained in 14068. Refer to comment 2 to EO 14068 for a discussion of the scope of the import ban on a cross-product basis. OFAC's reference to FAQ # 1019, in FAQ # 1070, leaves no doubt that guidance on the scope of the import ban as applied to other products controls the scope of the gold ban as well. Much turns on the meaning of "any Russian Federation origin good that has been incorporated or substantially transformed into a foreign-made product."

2) Note the exclusion for "gold of Russian Federation origin that was located outside of the Russian Federation prior to the effective date of this determination." It is not clear what OFAC would consider to qualify as reasonable due diligence...

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Determination Pursuant to Section 1(a)(i) of Executive Order 14068 (Effective June 28, 2022)

TURBOFAC Commentary (147 words)