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.
Notes:
1) This (particularly illuminating) guidance letter has implications for the scope of the exemption for transactions ordinarily incident to travel, as well as the relationship between 560.204 of the ITSR (exportation of services) and 560.320 (the definition of "Iranian accounts").
The redactions make it unclear whether the U.S. citizen applicant is actually "ordinarily resident" in Iran, and it seems as though OFAC is not sure either, so OFAC answers the questions both ways.
The export of services to a person "ordinarily resident" in Iran constitutes an export "to Iran" (560.204/560.410) even if the person in Iran is a "U.S. person.” The ordinarily resident in...