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) Read in conjunction with United States v. Griffith (1:20-cr-00015) (2021); OFAC "Licensing Determination". From a strictly legal basis standpoint, this is one of the most extraterritorially aggressive indictments of which we are aware. The indictment is of two non-U.S. persons, in connection with actions with little to no apparent U.S. nexus other than that they involved a U.S. citizen (and the DPRK mission to the UN, in NYC).
The key part of the indictment reads as follows:
13. It was a part and an object of the conspiracy that ALEJANDRO CAO DE BENOS and CHRISTOPHER EMMS, the defendants, and others known and unknown, would and did provide and cause others, including a U.S. person, to provide services to the DPRK, without first obtaining the required approval of OFAC, in violation of 50 U.S.C. § 1705(a), 31 C.F.R. §§ 510.206(a),