Notable OFAC Regulatory Provisions - 31 CFR § 560.516 Payment and United States dollar clearing transactions involving Iran (2006, Iran)

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 (825 words)

Notes:

1) THE UNANNOUNCED CHANGE IN THE SCOPE OF THE NOTION OF AN EXPORT OF "SERVICES" TO A SANCTIONED COUNTRY

This is the section of the (now ) that contained what is referred to as the "U-turn" general license. The section, which was substantially modified in 2012 when the ITR were reissued as the ITSR, is notable in part for support for the proposition that the scope of the term "service" has been something of a moving target over the past decade or so.

The provision authorizes United States depository institutions to process transfers of funds to or from Iran if:

"[t]he transfer arises from an underlying transaction that is not prohibited by this part, such as a non-commercial remittance to...

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31 CFR § 560.516 Payment and United States dollar clearing transactions involving Iran (2006, Iran)

TURBOFAC Commentary (825 words)