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 Treasury Targets Vessels Delivering Oil Derivatives to the Houthis (Press Release) (entities designated for acting outside scope of wind down GL). This appears to be the first time ever that OFAC has designated an entity while explicitly noting that the conduct resulting the designation qualified for a recently expired wind down GL (“Maisan finished discharging its cargo and departed Ras Isa on April 8, four days after the expiration of OFAC’s GL 25A”). Designations for transactions that do not qualify for a wind down GL but would have qualified for wind down GLs for U.S. persons when such GLs were still valid are extremely rare, and here OFAC explicitly calls out the fact that an otherwise applicable wind down GL was valid just four days prior to the sanctionable conduct taking place. The unusual step taking in this...