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) Correspondence clarifies the commonly-misunderstood [1] fact that the jurisdictional basis for control over Iran's access to the U.S. financial system is not that banking transactions involve dollars per se, but that they typically require U.S. persons to, e.g., export financial services to Iran (560.204) or otherwise "deal in" property in which blocked persons have an interest (560.211, in the case of Iran).
The statement that OFAC does "not exercise sanctions jurisdiction over transactions denominated in U.S. dollars" is true of physical dollars as well as offshore electronic dollar clearing and other types of book transfers that do not involve the U.S. financial system, but note that since the drafting of this letter OFAC appears to take a more aggressive stance on what constitutes involvement of the U.S. financial system when it comes to offshore book transfers. See comments to...