OFAC Interpretive Guidance/Licenses - Review of U.S. Treasury Department’s License to Convert Iranian Assets Using the U.S. Financial System” – Majority Report of the Senate Permanent Subcommittee on Investigations

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 (5286 words)

Notes:

The "Extinction of Interest" Concept, "Indirect Exports of Financial Services" and the Senate Majority Report of the Senate Permanent Subcommittee on Investigations on OFAC’s License to Convert Iranian Assets Using the U.S. Financial System; and Associated interpretive Guidance.

In this commentary we explain that, while the Senate Report omits discussion of the issue, some of the interpretive guidance issued by OFAC that the report refers to was almost certainly an application of the "comes to rest"/"extinction of interest" principle seen in Case No. IA-[REDACTED] (Patton Boggs LLP), Jan 5, 2011) and Case No. IA-2012-(Chicagoland Foreign Investment Group, LLC), except applied with what may be a far more significant effect. We are in the process of seeking certain of the underlying documents referred to in the report via FOIA.

Essentially, it appears as though OFAC acknowledged that the Central Bank of Iran...

Welcome!

Welcome!

Review of U.S. Treasury Department’s License to Convert Iranian Assets Using the U.S. Financial System” – Majority Report of the Senate Permanent Subcommittee on Investigations

TURBOFAC Commentary (5286 words)