U.S. Sanctions Target Cuba’s Military Regime, Elites (Press Statement)

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 (216 words)

Notes:

1) This is the first designation notice issued under 14404. While it does not include designations that would qualify as “secondary sanctions” enforcement actions as described in Introductory Note Common to all Derivative Designation Notices ("De Facto" Secondary Sanctions) Included in the Research System (System Ed. Note)), the notice is nonetheless notable insofar as the “Sanctions Implications” section appears to signal that the targeting risk under the EO is concentrated in “engag[ing] in transactions with persons designated pursuant to E.O. 14404 – or [] operat[ing] in the energy, defense and related materiel, metals and mining, financial services, or security sector of the Cuban economy, as identified in E.O. 14404.” Strictly speaking, any transaction involving the provision of goods or services to a “Government of Cuba” person is sanctionable under the material support provision in EO 14404, and a...

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U.S. Sanctions Target Cuba’s Military Regime, Elites (Press Statement)

TURBOFAC Commentary (216 words)