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) Note Common to Case No. IA-15877, Case No. IA-2012-299441-1, Case No. IA-2013-303511, Case No. IA-15582, License No. IA-15582 and Case No. IA-2012-(Chicagoland Foreign Investment Group, LLC) concerning "passive shareholding" and the import/export of services to and from Iran.
The guidance letters referenced in the title to this note all address the situation of an Iranian seeking to come to the U.S. who appears to own equity in an Iranian company. Three letters have a version of the following:
"a U.S. person who is a passive shareholder in an Iranian company who does not hold a management or board position, and who made the investment prior to becoming a U.S. person, would not necessarily be regarded by OFAC as violating the ITSR; however, should that...