Enforcement Release: An Unnamed Individual (23)

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 (195 words)

Notes:

1) This enforcement action is notable for being the second highest penalty ever assessed to an individual (the highest having been issued not long prior, see Enforcement Release - An Unnamed Individual (21)). From a legal basis perspective, the Enforcement Release is notable for the activities OFAC describes as exportations of services to Syria. Namely having “reviewed and approved operational and employee expenses; received, modified, and approved budgets; and signed company financial statements…participated in board and shareholder meetings and [been] involved in personnel management, including the hiring, promotion, and termination of employees, and day-to-day matters such as maintenance activities” for Syrian entities. Query; given the extent of the activities described over a three year period, how does OFAC calculate a total of only 20 “apparent violations”?

2) Another notable aspect of the enforcement action is that the legal basis for it...

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Enforcement Release: An Unnamed Individual (23)

TURBOFAC Commentary (195 words)