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.
While the details concerning the sanctions related portion of the CTC Media (“CTC”) case are not laid out anywhere in a cohesive, narrative form, what can be pieced together from the totality of CTC’s 2014-2016 filings with the SEC constitutes what appears to be the best evidence on public record of how OFAC treats a wide variety of issues pertaining to a situation in which blocked persons are substantially involved in a publicly traded, U.S.-based company. The CTC Media case also involves treatment of blocked, U.S.-based holdings in a takeover context, confirming the broad applicability of the principles discernible from Letter in re: Nokia Corporation Proposed Acquisition of Alcatel Lucent (2015). The value of the case is derived partially from direct reporting by CTC on what OFAC had told the company, partially from the context of the filings, which make it clear that OFAC was intimately involved...