OFAC Executive Order 13671 - Taking Additional Steps to Address the National Emergency With Respect to the Conflict in the Democratic Republic of the Congo (July 8, 2014)

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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.

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TURBOFAC Commentary (561 words)

Notes Common to EOs 13671 and 13413

1) The Democratic Republic of the Congo sanctions regulations are based on two Executive Orders (EO 13413 of October 30, 2006 and 13671 of July 8, 2014). There is no prohibition contained in either of the two that has not been incorporated in the sanctions regulations.

EO 13413 is a relatively straightforward -based EO, with IEEPA exemptions other than donations applicable. EO 13671 of July 8, 2014 amends the 2006 EO to add certain primary designation criteria, to adds an explicit "evasion" prohibition, and, most importantly, use UNPA as part of the authority for the sanctions regulations as a whole. The import of this is that, as is clarified by 547.206 (see also comments thereto), the ordinary IEEPA exemptions do not apply with respect to SDNs...

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Executive Order 13671 - ​Taking Additional Steps to Address the National Emergency With Respect to the Conflict in the Democratic Republic of the Congo (July 8, 2014)

TURBOFAC Commentary (561 words)

Executive Order 13671 - Taking Additional Steps to Address the National Emergency With Respect to the Conflict in the Democratic Republic of the Congo (July 8, 2014)