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) Compare the scope of this GL with, for example, the 560.508 (ITSR). This GL would appear to authorize both the actual sending of mail to an SDGT, the payment to a third-party common carrier for the delivery of the mail, and, presumably, the actual delivery of the mail itself.
Note that there are no personal communications or informational materials exemptions in the GTSR. Refer to General Note on the Lack of Berman Amendment Exemptions for the GTSR. Unlike IEEPA, UNPA permits the prohibition of communications between the U.S. and persons designated pursuant to an authority relying on UNPA. This means that, unlike the case with the mail-related GLs in embargo programs, which authorize mail treated transactions to the extent that they are not otherwise exempt, this GL "occupies the field" of permissible mail-related transactions involving SDGTs. As a result, the scope of the license, for "personal communications not involving a transfer of anything of value," was chosen by OFAC of its own volition, not mandated by the IEEPA exemption that is phrased in virtually identical language.
Query why this GL exists. It is possible that OFAC considered that, UNPA notwithstanding, a blanket prohibition on all telecommunications transactions with SDGTs would either i) not withstand First Amendment scrutiny, or otherwise ii) could not be justified as within the scope of the U.N.-related sanctions that serve as the basis for invoking UNPA as an authority for the GTSR in the first place.
2) See General Note on General Licenses for Transactions Related to Telecommunications and Mail.