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.
A common question that arises in the context of U.S. banks dealing with third-country persons that engage in sanctions-implicating dealings outside of U.S. jurisdiction is whether, and to what extent, U.S. persons must ensure that they do not deal in proceeds that are linked to or derived from such sanctions-implicating activities. As described below, the weight of evidence strongly suggests that OFAC does not interpret its prohibitions broadly in this context, be it in the case of blocking or general embargo prohibitions.
We first note that, when it comes to outward transfers of funds to third country persons that are known to engage in sanctions-implicating transactions, OFAC’s longstanding practice is to consider such transactions prohibited where (i) funds are earmarked for sanctions-implicating activity, or (ii) the non-sanctioned third...