OFAC FAQ (Current) # 545 - Section 228 (CAATSA)

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 (1144 words)

Notes:

1) This FAQ interprets elements of the secondary sanctions in SSIDES Sec. 10 (as amended by Sec. 228 of ) that, as of 5-5-22, have been implemented into the (see 589.201 and 589.413). The new FAQ # 545 is like FAQ # 542, but it handles “significant transaction” for section 10(a)(2)(A)) of SSIDES. It references the new provisions of the URSR dealing with secondary sanctions, but from a substantive standpoint, there is no difference between FAQ # 545 as it exists now and as it existed prior to the reissuance of the URSR.

i) KNOWINGLY

With respect to the term "knowingly," that knowledge qualifier is defined consistent with the definition of that term used by OFAC in all other secondary sanctions contexts....

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OFAC FAQ (Current) # 545 - Section 228 (CAATSA) (PDF contans all versions)

TURBOFAC Commentary (1144 words)