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.
As discussed in the "General Background Note on the Chronology of Guidance and interpretive Rulings Related to the Informational Materials Exemption and Publishing", this is one of the three interpretive Rulings from September, 2003 (030915-FACRL-IA-09, 031014-FACRL-IA-10 and 031002-FACRL-IA-11) that were removed from OFAC's index of interpretive rulings as a result of OFAC's April - July, 2004 expansion of the scope of the Berman Amendment through 040405-FACRL-IA-15, 040706-FACRL-IA-16 and 040719-FACRL-GN-01.
MARKETING
This particular guidance was effectively overruled by 040706-FACRL-IA-15. 040706-FACRL-IA-15 was in turn superseded by OFAC's 2016 Publishing Guidance, which appears to turn the substantive clock back to the time at which this guidance, which takes a narrower view of the scope of the Berman Amendment, was OFAC's prevailing view. [Note that the reason why this guidance is discussed specifically in...