OFAC Interpretive Guidance - Certain OFAC Correspondence Reproduced in Complaint in Bank Soyuz v. Office of Foreign Assets Control

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 (486 words)

Notes:

1) Correspondence derives from Complaint filed in Bank Soyuz v. Office of Foreign Assets Control, Case No. 1:05CV01073 (D.D.C.). See original PDF. For commentary on unblocking licenses issued in connection with litigation generally, see General Note on, and Notable Examples of, Specific Licenses Issued Pursuant to Unwritten Licensing Policies.

Against the background of the now-repealed Sudanese Sanctions Regulations, in which the Sudanese Government was blocked, this was a lawsuit brought against OFAC in connection with a payment made by a non-U.S. person, through a U.S. bank, with the beneficiary bank being a blocked Sudanese Government entity and the ultimate beneficiary of the payment being a (apparently) non-blocked Sudanese person. Apart from the involvement of the U.S. intermediary bank, the underlying transaction had nothing to do with the U.S. In addition to the blocking provision pertaining to the Sudanese government (538.201),...

Welcome!

Welcome!

Certain OFAC Correspondence Reproduced in Complaint in Bank Soyuz v. Office of Foreign Assets Control

TURBOFAC Commentary (486 words)