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 also extends the Shah Deniz exemption for parts of EO 13846 that represent pure-IEEPA-based broadenings of sanctions beyond the authorities of IFCA and the TRA. See Sec. 1(a) of 13846, all of which is covered by Sec. 10 of the EO. Notably, the exemption applies to the broad sanction at Sec. 1(a)(iii) of EO 13846, for which there is no explicit agricultural exemption.
2) Note that explicit references to Shah Deniz in the ITSR are implementations of the statute-wide waivers in IFCA and the TRA for that project. OFAC's other statements concerning the project, e.g. the 2012 Shah Deniz Consortium Industry Guidance, are interpretations of the scope of the basic prohibitions of the ITSR. See General Note on “Indirect Financing,” or Investments in Third Country Companies that do Business with Sanctioned Parties (System Ed. Note).
3) Substantially similar FAQ archived; see FAQ # 222.
[10-27-2020 update] - See note 5 to Treasury Sanctions Key Actors in Iran’s Oil Sector for Supporting Islamic Revolutionary Guard Corps-Qods Force, discussing the issue of the continued validity of the NIOC-related exception after the designation of that entity pursuant to EO 13224 on 10-26-2020.