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) PRESENTATIONS AND TALKS “DRAWN” OR DERIVED FROM EXEMPT INFORMATIONAL MATERIALS
The letter seeks to confirm that “standard academic presentations and talks by [university] faculty members” are, themselves, exempt “informational materials” when they are drawn from exempt informational materials. Here, the subject of the conferences is civil engineering.
OFAC says that “attendance at and participation in conferences in Iran, including the presentation of academic papers in Iran based on published materials that are from open and public domain literature, as described in the Application, would be prohibited by sections 560.201 and 560.204 of the ITSR unless specifically licensed by OFAC.”
In other words, the fact that a presentation is “drawn from” pre-existing informational materials—i.e. materials fully created and in existence prior to the sanctions-implicating activities—does not mean that...