31 CFR § 515.206 - Exempt transactions (1999, Cuba); FR Notice Implementing 1989 Version of the Berman Amendment in the CACR and FACR (54 FR 5229, Feb 2. 1989)

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 (1157 words)

Notes:

1) The "background" section of the FR Notice that implements the first (narrower) version of the Berman Amendment is notable for its sweeping statement, otherwise difficult to find on record, that "[f]inancial and other transactions directly related to the physical importation and exportation of tangible informational materials are authorized. [As are] [t]ransactions relating to the dissemination of informational materials [...] such as copying. dubbing, and translating."

These "examples" of what constituted transactions with the scope of the Berman Amendment concerning informational materials were first inserted in the and shortly after the original 1989 version of the Berman Amendment was enacted, and remained in the CACR up through 2016, when the relevance of the examples was diminished by the addition of a general license for, among other things,...

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31 CFR § 515.206 - Exempt transactions (1999, Cuba); FR Notice Implementing 1989 Version of the Berman Amendment in the CACR and FACR (54 FR 5229, Feb 2. 1989)

TURBOFAC Commentary (1157 words)