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.
1) OFAC distinguishes between secondarily sanctioned entities placed on the Part 561 list (Correspondent Account or Payable-Through Account Sanctions List (the "CAPTA List")), such as Kunlun, that have not also been designated as SDNs. Because Kunlun is not designated, the bank itself is not subject to secondary sanctions. What OFAC seems to have in mind here is something akin to the diversion of funds to Iran as a result of dealings with Kunlun.
Note however that more recent FFI-based CAPTA secondary sanctions apply to dealings with persons that have been derivatively designated for Iran-related dealings, whether or not the derivatively designated persons are Iranian and whether or not they have the [SDGT] or [NPWMD] tags. See Sec. 2(a)(ii) of EO 13846.