OFAC Interpretive Guidance - FAC- No. C-142787 (Application included in original PDF)

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.

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TURBOFAC Commentary (1861 words)

Notes:

1) See original PDF for the application and related correspondence, including the non-binding MOU at p. 19.

For context of discussion on the significance of this document in context, see General Note and Associated Scenario Matrix re: the Legal Status of Discussions, Negotiations, Contracts and other Pre-transactional Activities (System Ed. Note), as well as General Note on the Blocking of “Contracts” and the Determination of Persons Having an “Interest” in “Contracts,” and comments to Civil Enforcement Information - ExxonMobil Corporation (2017). On the basis of ExxonMobil Corporation (2017) and FAQs stating that "negotiation" with blocked parties is prohibited this guidance would appear to be overruled. But that is not necessarily the case. Note that this guidance interprets the now-repealed , in particular a prohibition (500.201) that was essentially identical to the current

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FAC- No. C-142787 (Application included in original PDF)

TURBOFAC Commentary (1861 words)