OFAC Regulatory Provisions - Appendix A to Part 569

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 (1608 words)

Notes:

*Update. On Oct. 23, 2019, OFAC de-listed all five entities and individuals blocked pursuant to the . The below was drafted prior to the delisting.

*On Jun 5, 2020, OFAC issued abbreviated regulations implementing the EO, which is now Appendix A to Part 569—Executive Order 13894.

1) INTRODUCTION; RELATIONSHIP TO PRE-EXISTING SYRIA-RELATED SANCTIONS

This EO, issued in response to actions by the Turkish military in Northeastern Syria, is highly irregular for a number of reasons discussed below, but in general does not present any novel legal issues or sanction types.

First, note that the EO is a sanctions regime completely distinct from the pre-existing Syria sanctions, which are generally a response to actions taken by the Syrian Government. OFAC has gone as far as giving the EO 13894 sanctions regime its own landing page on the...

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Appendix A to Part 569—Executive Order 13894

TURBOFAC Commentary (1608 words)