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.
11-22-22 Update. The notes below were drafted prior to OFAC releasing the Determination Pursuant to sections 1(a)(ii), 1(b), and 5 of Executive Order (E.O.) 14071 and associated guidance. See generally Consolidated Comment on the Prohibitions on Certain Services as They Relate to the Maritime Transport of Crude Oil of Russian Federation Origin (the Price Cap). The comments below have not been edited in light of the release of the 11-22-22 items, but several are referenced in the Consolidated Comment as having ongoing significance.
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1) These comments were made after the publication of the Preliminary Guidance on Implementation of a Maritime Services Policy and Related Price Exception for Seaborne Russian Oil (Preliminary Guidance), but before the imposition of the prohibition itself. There are a few notable aspects of the comments excerpted....