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) See 501.807, and comments thereto. This guidance was adopted to account for the fact that 501.807 of the RPPR does not set out procedures for the State Department’s reconsideration of its own designations as an “adjudicating agency” (thereby leaving State Department designations vulnerable to judicial challenge (see https://storage.courtlistener.com/recap/gov.uscourts.dcd.257530/gov.uscourts.dcd.257530.1.0.pdf, a Jul 17, 2023 complaint which may have led to the SDN’s September 14, 2023 removal from the SDN list (see https://ofac.treasury.gov/recent-actions/20230914).
2) The guidance specifies that:
Receipt of payment for such services from sources outside of the United States is also authorized by GL in many programs and is routinely authorized by specific license in others. Even if the person making the payment to the lawyer is not the SDN (such...