Introduction to the 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 (325 words)

Notes:

1) As a general matter, this “intro” document does not provide new guidance or otherwise make legally significant statements not otherwise found elsewhere, but there a handful of notable aspects to it that are highlighted below.

• P 1. Apart from this appears to be only OFAC has used the term “derivative designation criteria” in a way that is distinguishable from “secondary sanctions”. OFAC identifies “being owned or controlled by, or acting for or on behalf of, a blocked person or for providing material support to an individual or entity” as “derivative designation criteria,” while “secondary sanctions” are “type of sanction used to specifically and explicitly target non-U.S. persons, such as non- U.S. banks, for engaging in certain transactions with blocked persons or other specified activities.” In practice the distinction between the two can be minimal. See General Note...

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Introduction to the Office of Foreign Assets Control

TURBOFAC Commentary (325 words)