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) The Payward, Inc. d/b/a Kraken enforcement action differs from the three cryptocurrency-related ones that precede it (Bittrex, Inc., BitPay, Inc and BitGo, Inc.) in that it only invoices one sanctions program, instead of five or six. As is common for genre, OFAC finds violations on the basis of services provided to persons with Iran-associated IP addresses, i.e. persons presumed to be "in" (even if not necessarily "ordinarily resident" in Iran). OFAC notable states that the individuals "appeared to have been located in Iran at the time of the transactions," recognizing that IP addresses alone are not necessarily definitive proof of location (but good enough to establish a functionally irrebuttable presumption of physical presence in Iran).
2) This appears to be the first time that OFAC reports a forward-looking compliance spending pledge in an enforcement release. Mitigating factors are fairly common for the...