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.
General Note on the Prohibitions on Dealings in “New Debt” of Certain Sanctions Targets (System Ed. Note)
I. BACKGROUND
II. 50% RULE
III. WHAT IS “DEBT”?
a. “Loans” and “Extensions of Credit”
b. Other Examples of “Debt”
c. Examples of what OFAC Regards as Not Being “Debt”
IV. WHAT IS DEBT “OF” A SANCTIONS TARGET?
V. WHAT IS “NEW” DEBT
a. The Initial Date of “Issuance” of Debt, Common Situations
b. The Initial Date of “Issuance” of Debt, Situations Where Debt is Issued After the Sanctions Effective Date Pursuant to a Qualifying Pre-Sanctions Agreement
VI. THE CONVERSION OF PRE-SANCTIONS OR OTHERWISE NON-PROHIBITED DEBT INTO PROHIBITED “NEW DEBT”
VII. WHAT IS A “DEALING” IN “NEW DEBT” OR “FACILITATION” THEREOF
VIII. CERTAIN OPEN INTERPRETIVE QUESTIONS
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General Note on the Prohibitions on Dealings in “New Debt” of Certain Sanctions Targets (System Ed. Note)
I. BACKGROUND
As of 11-25-22, there are substantively similar “new debt” prohibitions in four distinct...