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) The Guidance analyzes a set of transactions at the intersection of the Berman Amendment exemptions for travel and transactions ordinarily incident thereto (560.210(d)) and the exemption for informational materials transactions (560.210(c)).
With regard to OFAC's declaration that "the Regulations do not prohibit [the advertisement of air service between the United States and Iran] unless they are undertaken at the behest of a person in Iran or an Iranian entity," compare FAC No. CU-156123, considering a Cuban travel company paying a U.S. person to broadcast advertising as being within the scope of informational materials exemption (i.e. where the travel exemption was not available). The reason why the advertising generally is not permitted is because OFAC deems it i) not ordinarily incident to travel, and ii) more of a service than a transaction incident to the import/export of informational materials, but...