Notable Fed. Reg. Notice (OFAC) - FR Notice Explaining Introduction of Internet Services General Licenses (75 FR 10997, Mar. 8, 2010)

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 (275 words)

Notes:

1) This FR notice explains the background for the first three internet services GLs issued by OFAC. In conjunction with Case No. MUL-271 and the preface to the GLs stating that they authorize transactions "[t]o the extent that such transactions are not exempt from the prohibitions of [the ITSR/SSR]," the notice is notable for the statement that the GLs were being issued "to ensure that the sanctions on Sudan and Iran do not have an unintended chilling effect on the ability of companies to provide personal communications tools to individuals in those countries." That way of characterizing the issuance of the GL, suggesting that it served the purpose of removing doubt as to whether the authorized transactions were exempt, rather than to completely change the scope of the pre-existing law, is one of several bits of evidence that OFAC has provided suggesting that at least some...

Welcome!

Welcome!

FR Notice Explaining Introduction of Internet Services General Licenses (75 FR 10997, Mar. 8, 2010)

TURBOFAC Commentary (275 words)