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) BACKGROUND
In a case related to a certificate of deposit issued by Citibank in the name of a deceased “Cuban National,” Citibank was asked by the court whether it could, given the restrictions of the CACR, produce the certificate of deposit in response to a discovery request.
Counsel for Citibank reports two “telephone opinions” of a person that, at the time, was a senior counsel in the OFAC Office of Chief Counsel. The opinions are notable for the reasons discussed below, in large part because we are aware of no other statement by OFAC directly speaking to the issues addressed one way or the other, but the evidence presented here of the OFAC opinions is obviously not as strong as a written opinion from OFAC itself would be. That said, the “telephone opinions” were provided about two...