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.
OFAC prohibits the exportation of “services” to all comprehensively embargoed countries and territories (see e.g. 560.204 (Iran)), the “contribution or provision of…services…to, or for the benefit of any [blocked] person” (see e.g. 555.405), and “services performed in the United States or by U.S. persons, wherever located…[w]ith respect to” blocked property (id). Same applies for the importation of services from embargoed countries and the receipt of services from blocked persons.
OFAC’s regulations do not define “service” or “services,” a term the definition of which is outcome determinative for many difficult OFAC-related sanctions questions. As evidenced by the below, the term is very broadly construed, but not endlessly broad to as to include, in a categorial fashion, any action or omission that happens to be...