Case No. IA-2018-XXXXX-X (4/16/2018)

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 (771 words)

Notes:

1) BACKGROUND

Correspondence released on Twitter by the applicant, the "Founder" and "CEO" of the company that owns the "Gap Messenger app" referred to in the letter [1]. It is not entirely clear whether, as of the time at which the letter was drafted, the applicant (Anjidani) was a person that OFAC considered to be “in” or “ordinarily resident in” Iran. Anjidani appears to have lived in the UK since 2005 [2], thereby rendering him a person that would generally not be considered “ordinarily resident” in Iran. The guidance letter, however, proceeds without assuming anything about the “ordinarily resident” status of the applicant one way or the other. The Gap Messenger app, which appears to serve a primarily Iranian/Farsi-speaking market, was one of several taken off of Apple’s app store prior to the application.[3]

2) NON EXPORT-RELATED DEALINGS IN “IRANIAN ORIGIN APPS” ARE...

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Case No. IA-2018-XXXXX-X (4/16/2018)

TURBOFAC Commentary (771 words)