OFAC Correspondence - OFAC SpaceX Litigation Correspondence (2014) (Related correspondence included in original PDF)

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 (552 words)

Notes:

1) Context of correspondence is an injunction issued by a U.S. court (see attached PDF) against a U.S. company dealing with a Russian company purported to be controlled by an , but where there was no allegation of ownership. As with other ordinary -based programs, the relevant contained designation criteria allowing for the blocking of "persons determined by the Secretary of the Treasury, in consultation with the Secretary of State...to be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly... a person whose property and interests in property are blocked pursuant to [EO 13661]." As OFAC notes, however, this takes effect only upon an affirmative determination, rather than by operation of law. See General Note on the Distinction...

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OFAC SpaceX Correspondence (2014) (Related items included in original PDF)

TURBOFAC Commentary (552 words)