[{"text":"<strong>Litigation<\/strong> Involving Sanctioned Persons and Blocked Property (Incl <strong>Attachment<\/strong>); <strong>Legal Services and Compliance-Related Advice<\/strong> Provided to and With Respect to Sanctioned Persons","state":{"value":"","checked":false,"expanded":false,"disabled":false,"disabledCustom":true,"count":0,"max":0},"children":[{"text":"<strong>Litigation<\/strong> Involving Sanctioned Persons and Blocked Property Generally","state":{"value":"litigation","checked":false,"count":0,"max":0}},{"text":"The <strong>Attachment<\/strong> of Blocked Property; Terrorism Risk Insurance Act (TRIA)\/ Foreign Sovereign Immunities Act (FSIA)","state":{"value":"attachment","checked":false,"count":0,"max":0}},{"text":"The Provision of <strong>Legal\/Compliance-Related Advice<\/strong> to Sanctioned Persons or with Respect to Blocked Property","state":{"value":"legaladvice","checked":false,"count":0,"max":0,"notes":"This search criterion covers most items that deal with the scope of the boilerplate general license for the provision of legal services to blocked persons."}}]},{"text":"Items Related to the Protection of and Dealing in Intellectual\nProperty Rights With Sanctions Implications <strong>(IP Rights)<\/strong>","state":{"value":"iprights","checked":false,"count":0,"max":0}},{"text":"Items Related to <strong>Crypto Assets and Digital Currencies<\/strong>","state":{"value":"crypto","checked":false,"count":0,"max":0}},{"text":"Items Related to Immigration To and From Sanctioned Countries (Iran and Syria in Particular)","state":{"value":"immigration","checked":false,"count":0,"max":0,"notes":"Relevant background reading: <a href=\"https:\/\/sanctions.org\/turbofac\/research\/OFAC-general-note-on-the-immigration-related-gls-in-the-itsr-and-sysr-and-dealings-with-sanctioned-iranian-and-syrian-individuals\" target=\"_blank\">General Note on the Immigration-related GLs in the ITSR and SySR, and Dealings With Sanctioned Iranian and Syrian Individuals Lawfully Present in the U.S. (System Ed. Note)<\/a>"}},{"text":"Items Explicitly or Impliedly Addressing <strong>Due Diligence\/Compliance Program<\/strong> Expectations","state":{"value":"","expanded":false,"disabled":false,"disabledCustom":true,"checked":false,"count":0,"max":0},"children":[{"text":"All items in parent category","state":{"value":"diligence","checked":false,"count":0,"max":0}},{"text":"<strong>Enforcement<\/strong> Actions in Which <strong>Diligence or Compliance Program Failure<\/strong> was Highlighted","state":{"value":"DILFAIL","checked":false,"count":0,"notes":"This criterion includes all enforcement actions in which OFAC highlighted at least one kind of due diligence failure. Refer to the enforcement action search module for more granular diligence-related search criteria, broken down by type of due diligence failure.","max":0}},{"text":"Items Related to <strong>Screening;<\/strong> Automated and Otherwise","state":{"value":"screening","checked":false,"count":0,"max":0}},{"text":"Items Related to Expectations on <strong>Intermediary<\/strong> Financial Institutions","state":{"value":"intermediaries","checked":false,"count":0,"max":0}},{"text":"FAQs and Other Guidance Documents Related Specifically to <strong>Compliance Programs<\/strong> in General","state":{"value":"complyprogram","checked":false,"count":0,"notes":"The scope of this criterion covers items that explicitly or impliedly provide details on compliance program expectations beyond blanket, generic statements that having some sort of risk-based compliance program is expected.","max":0}}]},{"text":"Primary Sanctions Prohibitions and Certain <strong>\u201cPre-Transactional\u201d<\/strong> Activities, e.g. <strong>\u201cPreliminary Discussions\u201d<\/strong>, <strong>\u201cNegotiations\u201d<\/strong>, Entering Into <strong>Agreements, Invoicing<\/strong>","state":{"value":"","checked":false,"expanded":false,"disabled":false,"disabledCustom":true,"count":0,"notes":"Note that these same search criteria are also found in search criteria dealing with special recurring legal issues. For technical legal purposes OFAC uses the term \u201ctransaction\u201d to describe a broad range of activity that, in common parlance, falls well short of a consummated \u201ctransaction\u201d (i.e. an instance of buying or selling something; a business deal). The scope of this search criterion is limited to activities that, in a non-technical sense, would generally be described as \u201cpre-transactional,\u201d e.g. entering into a contract (without actually performing under it), executing a legal document; engaging in negotiations, merely issuing an invoice, etc. Note that all of the cases within the scope of this search criterion are covered by at least one other one, as OFAC has different ways of legally characterizing \u201cpre-transactional\u201d activities, e.g. as \u201cattempts\u201d to violate substantive prohibitions, \u201cconspiracies\u201d do so, dealing in services of blocked persons, etc. Note that most \u201cattempt\u201d violations are outside the scope of this search criterion, e.g. instructions to banks to make prohibited payments; the making of shipments of (interdicted) goods. For relevant background reading, refer to <a href=\"https:\/\/sanctions.org\/turbofac\/research\/OFAC-General-Note-contracts-negotiations-discussions\" target=\"_blank\">General Note and Associated Scenario Matrix re: the Legal Status of Discussions, Negotiations, Contracts and other Pre-transactional Activities<\/a> (System Ed. Note). Because \u201cpre-transactional\u201d is not a legal term, but rather a heuristic used for classification purposes, there is room for debate as to what should and should not be within the scope of the search criterion.","max":0},"children":[{"text":"In General (Returns All Documents Within Parent Category)","state":{"value":"CNIPT","checked":false,"count":0,"max":0}},{"text":"Issues Related to <strong>Negotiations<\/strong> Requiring a License and <strong>\u201cPreliminary Discussions\u201d<\/strong> Outside the Scope of Sanctions Prohibitions","state":{"value":"CNIPT-TALK","checked":false,"count":0,"max":0}},{"text":"Issues Related to <strong>Contracts<\/strong> (Entering Into; Performing Obligations Thereunder)","state":{"value":"CNIPT-contracts","checked":false,"count":0,"max":0}},{"text":"Issues Related to Other \u201cPre-transactional\u201d Activities, Incl. <strong>Corporate Governance\/Service on Boards of Directors<\/strong>)","state":{"value":"CNIPT-OTH","checked":false,"count":0,"max":0,"notes":"This search criterion also covers the direct and indirect involvement of sanctioned persons in otherwise permissible dealings with non-sanctioned entities."}}]}]