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).
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1) The implication of this GL, confirmed by, e.g. Case No. IA-16801, is that OFAC would consider the mere maintenance of a U.S.-based account for a person "in Syria" to constitute an "export" of a "financial service" to Syria, prohibited unless otherwise authorized, even if the person in Syria is a U.S. citizen. This should include persons ordinarily resident in Syria, wherever located, as well as persons not ordinarily resident in Syria but "in Syria." Compare Case No. IA-16053, but note that the ITSR is structured differently than the SySR with respect to the operation of accounts (see 560.320 and 560.517).
2) With respect to the distinction between persons "ordinarily resident" in Syria and persons merely "in" Syria, note that 542.512 (personal remittances) only pertains to persons "ordinarily resident" in Syria. Presumably, a U.S. person merely "in Syria" transferring money to Syria from his or her own U.S.-based account would be exempt from regulation as a transaction ordinarily incident to Travel (542.211(c)). That would explain why OFAC did not specifically authorize those transactions.
3) Does the proviso at 542.515(b) mean that the accounts cannot be used to process transactions for persons ordinarily resident in Syria if the transaction would not qualify as a "noncommercial, personal remittance" even if the underlying transaction would be authorized by some other provision? The text of the regulations suggests that the answer is "no," but see Nov. 2014 Email from OFAC SC&E to Local Sudanese UNDP Staff in re: UNFCU Accounts.