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.
The issuance of the 2016 "Guidance on Certain Publishing Activities" is the latest substantial event in one long, conceptually contiguous public fight that OFAC has had with the publishing community generally over the scope of the informational materials exemption of the Berman Amendment. This guidance is difficult to understand without reference to the chronology generally, and how the latest guidance relates to all of the guidance previously issued on the scope of the Berman Amendment. The analysis of the substance of the guidance itself follows this general background note.
I. The 2003 Interpretive Rulings up Through the 2016 Guidance on Certain Publishing Activities
In 2003, when OFAC began publishing interpretive rulings on its website, OFAC issued the following rulings,...