OFAC Secondary Sanctions Enforcement - Equipment Development Department and Li Shangfu (China)

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.

TURBOFAC Commentary (823 words)

Notes:

1) The transaction resulting in the imposition of sanctions on the Equipment Development Department cannot be described as an "ordinary commercial transaction." Nevertheless, the imposition of sanctions here is notable insofar as this is the first use of a Russia-based secondary sanctions authority to block an entity in connection with an international trade transaction. Within the context of all secondary sanctions enforcement actions, this is one of a small handful of sanctions imposed as a result of a transaction that was not alleged to i) be illegal under international law or under the laws of any country with jurisdiction over the transaction, ii) be evasive/deceptive, iii) involve the U.S. in any way, or iv) otherwise be at odds with a UN Security Council resolution.

Sanctions imposed in situations meeting all of those criteria are rare.

2) The provision of

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Secondary Sanctions Enforcement Announcement - Equipment Development Department and Li Shangfu (China)

TURBOFAC Commentary (823 words)