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) Notwithstanding the sensitive nature of the transactions at issue, the iJet (UAE) portion of this designation notice appears to qualify as a proper "quasi-secondary sanctions" action (as described in Introductory Note Common to all Derivative Designation Notices Included in the Research System) The notice reports that the iJet designation was “taken in cooperation with the UAE government,” but there is nothing to suggest that iJet’s actions were illegal under UAE or any other country’s law. That OFAC highlighted the UAE government’s “cooperation” with the designation appears aimed primarily at conveying that OFAC did not designate the entity over the UAE government’s objection.
2) The designation notice is one of several examples of how the “acting on behalf of” designation criterion can be invoked in the context of otherwise arm’s length commercial transactions where the person designated is not acting...