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) As discussed in the "General Background Note on the Chronology of Guidance and Interpretive Rulings Related to the Informational Materials Exemption and Publishing", this interpretive ruling has remained on OFAC's website from 2003 up through the present, and therefore cannot be viewed as having been impacted by the portions of the 2016 Publishing Guidance that dealt with the scope of the informational materials exemption of the Berman Amendment.
This case, which expands on 030708-FACRL-IA-08 (presumably involving the same applicant), deals with information that would otherwise qualify as informational materials, i.e. info about the Iranian companies, but here the distinction is drawn between "enhancing" the manner in which pre-existing information is presented, vis-a-vis "enhancing" the information itself, where the former is exempt, and the latter prohibited.
Note that this guidance does not stand for the broad...