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) Compare MasterCard International Incorporated (failure to block and report credit card accounts of an SDN). As it relates to the reporting requirement component, this FOV appears aimed at stressing that "accurate reporting" is required by the RPPR, not just reporting. This appears to be the first time that OFAC has used inaccurate or inconsistent reports (otherwise filed in good faith) as a basis for finding an violation of the RPPR.
2) OFAC cites 591.202 of the VSR as the basis for the blocking regulation violations (Nodus engaged in three transactions totaling $50,271.29 in violation of § 591.202 of the VSR). 591.202 is the standard "Effect of transfers violating the provisions of this part" provision, and does not appear to have ever been cited as the...