31 CFR § 590.511 - Official business of certain international organizations and entities.

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 (304 words)

Notes:

1) This is a fairly standard "international organizations" , except that, unlike similar GLs it refers to "International Organizations and Other International Entities," as opposed to only the "United Nations, including its Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations". Compare e.g., Venezuela General License 20; 510.514. Some of the non UN-Related organizations listed appear in other GLs, and some are specific to this GL.

2) By its terms, the GL is not limited to activities in which a U.S. person is a party to an underlying transaction. This means that U.S. persons may engage in ancillary transactions that would be subject to the otherwise-applicable prohibitions, even if such activities pertain to a transaction involving no U.S. person.

3) See General Note on Exemptions and General Licenses for the “Official Business” of the U.S. Government (and/or United Nations) and Employees, Contractors, or Grantees Thereof. Note that the addition of "Other Entities and Bodies" to the UN GLs , which began with Burma General License Number 2 (March 25, 2021), appears to constitute a substantive addition vis-a-vis previous, otherwise similarly-worded UN official business GLs.

4) "International Centre for Settlement of Investment Disputes (ICSID) and Multilateral Investment Guarantee Agency (MIGA) are not specialized agencies in accordance with Articles 57 and 63 of the Charter, but are part of the World Bank Group," which is a "specialized agency". See https://www.un.org/en/pdfs/un_system_chart.pdf (https://archive.md/wip/Uz33k).

5) This provision was added to the in 2022, when the TCOSR were reissued as a "full" set of regulations, as opposed to the abbreviated version that had been in force. The inclusion of the GL is not mandated by statute or any .

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31 CFR § 590.511 - Official business of certain international organizations and entities.

TURBOFAC Commentary (304 words)