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 enforcement action continues the trend of OFAC penalizing corporate officers for activities taken within the scope of their employment. Compare Enforcement Release: Murad, LLC and Former Senior Executive of Murad, LLC (Individual).
2) From a legal basis standpoint, there are a few notable aspects of this enforcement action. It is the first that involves a U.S. person employee working for an entity of which a blocked person is CEO (but apparently not the owner). Compare FAQ # 398 (an entity controlled, but not owned, by a blocked is not blocked pursuant to the 50% Rule). Accordingly, is not categorically prohibited for the U.S. person employee to continue working for the company, but it could not engage in transactions in which the SDN CEO had an interest. Here, OFAC points specifically to six payments that were executed...