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) This "determination" and the FAQs published concurrently therewith largely mimic the 5-8-22 Professional Services Determination, 5-19-23 Architecture and Engineering Services Determination and 9-15-22 Quantum Computing Services Determination.
2) Unlike those determinations there is no parallel designation authority for persons operating in the IT/ IT support services and cloud-based services sectors of the Russian economy (compare e.g. Determination Pursuant to Section 1(a)(i) of Executive Order 14024 (Effective May 19, 2023)). That said, to some extent, many such persons may (or necessarily are) already operating in the “technology” sector of the Russian economy.
3) Two other notable distinctions between the 6-12-24 Tech Services Determination and other EO 14071-based services prohibitions referenced above are (i) the significantly delayed effective date of the prohibition (three months after issuance of the Determination), and (ii) the...