Case No. IA-2016-330121-1

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 (1648 words)

Notes:

1) Background

The litigation to which this guidance letter relates (see PDF file) involves an Iranian entity plaintiff suing a U.S. person in a U.S. court over the U.S. person’s alleged failure to return money to the Iranian plaintiff that was connected to the underlying transaction that was in violation of the . Indeed, the suit was filed only after the natural person Iranian owner of the plaintiff Iranian entity was imprisoned for a violation of the ITSR connected to the transaction at issue in the civil case (see Government's sentencing memorandum at p. 22 et seq. of the native PDF file). Specifically, the suit seeks restitution of a $390,000 "advance payment" made by plaintiffs to the U.S. person defendant company, which defendants evidently did not deny receiving and refusing to return.
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Case No. IA-2016-330121-1

TURBOFAC Commentary (1648 words)