Case No. WMD-11; Related State Department Correspondence; Notable Court Order

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 (949 words)

Notes:

1) BACKGROUND; OFAC LETTER

This guidance letter is, as of 10/2021, the only one on file that relates to the functionally defunct but still technically active . There are currently no persons designated pursuant to the WMDTCR, of which 539.201 is an import ban that applies to "the importation into the United States, on or after the effective date, directly or indirectly, of any goods, technology, or services produced or provided by a designated foreign person..."

In this case, the goods were purchased prior to the designation of the Xinshidai, but had not yet arrived at the U.S. port. Because the prohibition at 539.201 applies to "goods...produced...by a designated foreign person," they were within the scope of the prohibition even though they were purchased prior to the designation. The interpretation...

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Case No. WMD-11; Related State Department Correspondence; Notable Court Order

TURBOFAC Commentary (949 words)