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1) This is essentially the newspaper equivalent of 040405-FACRL-IA-15, which was explicitly superseded by OFAC’s 2016 Guidance on Certain Publishing Activities. This guidance was not explicitly referred to as superseded in the 2016 Guidance, but the substance and reference to 040405-FACRL-IA-15 leaves no doubt that it is, at least in part, superseded.
In particular, all actions described here that would have the effect of making an article substantively better—e.g. deleting "superfluous" text, correcting grammar and making an article "more understandable"—seem to have all been purposefully omitted from the copy and style activities that OFAC deems still-exempt in the 2016 guidance. As a general matter, it would appear that the reversal in policy from the time this guidance was issued to 7/2021 is cordoned off to prior statements interpreting the scope of what constitutes a "substantive...alteration" within the meaning of