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.
Compare with the ITSR's broad, IEEPA-based import ban (560.201, and comments thereto).
1) "ORDINARILY RESIDENT" TEST APPLIES FOR SERVICES
As is typical with IEEPA-based bans on exports and imports of services, the prohibition applies with respect to virtually all dealings with persons "ordinarily resident" in North Korea, irrespective of where in the world they may be at the time the service is rendered. See generally enforcement actions and guidance documents pertaining to 560.201 for guidance on the likely way in which this provision would be interpreted with respect to both imports of goods as well as services.
2) NO SUBSTANTIAL TRANSFORMATION RULE
The ITSR contains a few interpretive provisions defining the scope of the import...