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.
1) Digital currency analogue of FAQ 41, saying the same thing about blocked funds generally with respect to banks. Given the lack of a General License associated with this FAQ and presuming that this is permissible even if the customer itself is a blocked party, OFAC impliedly determines that a customer advising a blocked party does not constitute a "service" provided to the customer, or if the customer is not blocked, a service "with respect to" the blocked property. This suggests limitations to OFAC's expansive interpretation of what constitutes an impermissible discussion with an SDN (compare e.g. FAQ 547).
2) See OFAC Director A. Gacki; Interview Concerning Cryptocurrency Industry Compliance (Transcript), for a collection of notable statements concerning OFAC compliance expectations vis-a-vis the cryptoasset industry.