Case No. UKRAINE-EO13662-2018-358314-1 [Application included]

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 (426 words)

Notes:

1) The applicant university and faculty researcher—in this case a former professor and holder of an endowed chair in petroleum engineering at Texas A&M University [1]—inquire about the status of certain energy-related scientific experiments under the various Ukraine-related executive orders and, more specifically, SSI Directive 4.

At first glance it could appear as though the applicants misunderstood the Ukraine-related primary sanctions prohibitions to constitute something akin to a comprehensive embargo, but it is more likely that the textual breadth of SSI Directive 4 gave the applicants cause for concern. SSI Directive 4 prohibits the “indirect” exportation of “services” in “support of exploration or production for deepwater, Arctic offshore, or shale projects…that have the potential to produce oil in the Russian Federation” that involve certain persons subject to the SSI Directive 4.

The professor at issue, now deceased,...

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Case No. UKRAINE-EO13662-2018-358314-1 [Application included]

TURBOFAC Commentary (426 words)