OFAC FAQ (Current) # 501 - Cyber General License 1A, (the Federal Security Service)

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 (318 words)

Notes:

1) Typically, OFAC does not generally license a transaction type unless it considers the authorized transaction to be within the scope of a prohibition.

Here OFAC authorizes "Requesting, receiving, utilizing, paying for, or dealing in licenses, permits, certifications, or notifications issued or registered by the Federal Security Service." Characterizing "permits" as property in which the issuer has an interest is consistent with OFAC's past practice. "Requesting" the permits would also be prohibited but for the license as an "attempt" to deal in the property.

OFAC also generally licenses transactions incident to "[c]omplying with rules and regulations administered by the Federal Security Service." Even though OFAC ordinarily does not license that which would be permissible but for the license, here the usual caveat that the activities are licensed to the extent "otherwise prohibited" tends against a reading that OFAC considers...

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OFAC FAQ (Current) # 501 - Cyber-related Sanctions

TURBOFAC Commentary (318 words)