Use this field to filter the universe of available documents using a Google©-like search.

Different search types can be used to refine and improve the search results. Below is a list of examples showing which operators can be used.

We define "sanctions program" as being sanctions regulations found in 31 CFR Ch. V, except that when executive orders and/or statutes containing OFAC-administered authorities are not incorporated into regulations, such executive orders and/or statutes are considered separate "programs." In the case of North Korea, for example, we consider all executive orders incorporated into the North Korea Sanctions Regulations (NKSR) as being part of the (NKSR). The EOs incorporated into the NKSR are not separate “programs.” In the case of Venezuela, various Venezuela-related executive orders containing prohibitions have been incorporated into the Venezuela Sanctions Regulations, but we treat the incorporated EOs as separate "programs” in light of the particular way in which OFAC handles the general licensing for Venezuela. When a given document related to “derivative designation” criteria contained in an executive order fully incorporated into sanctions regulations, we treat any document pertaining specifically to the designation criteria as being part of the corresponding sanctions regulations. For example, documents dealing with the “material assistance” designation criterion in EO 13582 (blocking the Government of Syria) are treated as part of the Syrian Sanctions Regulations. For relevant background reading, see General Note on the Relationship Between Executive Orders, General Licenses and Sanctions Regulations Issued Pursuant to a Common National Emergency (System Ed. Note).

NOTES:

i) The search criteria in this module are generally limited to documents that provide some interpretive value in connection with a given issue. It is therefore not the case that all documents touching on a given subject are within the scope of the search criteria.

ii) The connection between a given search criterion and returned document may not always be evident from the face of the returned document. Where this is the case, refer to comments to each document for an explanation as to why the document deals with a given legal issue. In some cases, the connection between a given document and a legal issue is only implied, e.g. where OFAC states that a certain transaction is not prohibited, without providing a prohibition-by-prohibition analysis but implying that the transaction would not fall within the scope of any prohibition.

iii) There is substantial overlap between the scope of some of the search criteria. For example, “indirect financing” is its own search criterion, but is also “facilitation.” “Indirect financing” is a form of “facilitation,” but may also be characterized in other ways, such as dealing in blocked property, or an “export” of financial services to a prohibited designation.

iv) For ease of reference, certain search criteria are placed in multiple subcategories.

v) These search criteria are divided into two broad categories. One pertains only “primary sanctions prohibitions,” where “prohibited” conduct refers to violations of American law for which the potential penalties are civil fines or criminal prosecution. The other pertains only to “secondary sanctions” authorities and “derivative designation” criteria delineating the scope of certain conduct that is “sanctionable,” irrespective of whether the conduct is also “prohibited” pursuant to a primary sanctions prohibition. For relevant background reading, see General Note on the terms “Exempt,” Authorized,” “Licensed,” “Prohibited,” “Not Prohibited” and “Sanctionable” (System Ed. Note); General Note on Secondary Sanctions and “Derivative Designation” Criteria; Identification of the Gap Between the Theoretical and Practical Scopes of Authorities Targeting Transactions with no U.S. Nexus; Enforcement Risk Management (System Ed. Note).

This search bar allows you to retrieve all documents that are associated with a given legal authority (e.g. regulatory provision, general license, executive order or statute). In most cases, the relationship between a given item and the associated legal authority is obvious, e.g. when an FAQ discusses a specific general license, but in other cases the relationship is not explicit. In such cases we generally explain the relationship in the commentary associated with the relevant item.

In addition, please note the following:

(i) For all six-digit regulatory provisions, we have omitted the "31 CFR §" in "31 CFR § 5XX.XXX."

ii) We occasionally tag an item at the level of the relevant subsection, e.g. "560.204(b)" and "560.204," but this is not always done. If you want to search all items that we have associated with "560.204(b)," your search should be for "560.204."

(iii) If you want to search by executive orders, or specific sections of executive orders, note that the format we use is, for example, "E.O. 13846-2(a)(i)," which would refer to subsection 2(a)(i) of EO 13846. The dash after E.O. separates the number of the EO from the section addressed. As with discrete regulatory provisions, we sometimes tag items dealing specifically with executive orders at level of the discrete subsection, but it is generally done at the section level, so a search for everything dealing with subsection 2(a)(i) of EO 13846 should be "E.O. 13846-2."

(iv) For statutes, we generally use the acronym found in the main "Acronym List" linked to at the top of the main webpage, followed by "Sec. ####." So, for all items dealing with Section 1444 of the Iran Freedom and Counter-Proliferation Act of 2012, you would enter "IFCA Sec. 1244." As with discrete regulatory provisions, we sometimes tag items dealing specifically with statutes at level of the discrete subsection, but it is generally done at the section level, so a search for everything dealing with subsection (c) of Section 1244 of IFCA should be "IFCA Sec. 1244."

(v) Unlike all other search criteria, where there are two, there is only one number in parentheses beside each discrete legal provision in the legal provision search category. That number represents the total number of items in the database associated with each provision. That number is static, and does not respond to the selection of other search criteria. For example, if you select 560.201, and the number beside that provision is (100), that means that 100 items are tagged as relating to 560.201 . However, if you select 560.201 in conjunction with the 2019' Document Year criterion you will, the number that appears in the main "#,###/#,### Items" search button will represent the total number of items issued or last amended in 2019 that deal with 560.201.

All of the criteria found in the broad categories above—e.g. document year, sanctions program at issue, etc.—may apply to civil enforcement action documents, but the criteria in this category ONLY apply to civil enforcement actions. If you have spent time sorting items according to the criteria above, and then select criteria in this category, the only documents that will be returned are those that relate to civil enforcement action-related documents. If you run a search without clicking any of the criteria in this category, you will still return all of the civil enforcement action-related documents in the Research System, as applicable. If you want to limit the scope of the enforcement action-related documents to those involving violations of certain sanctions programs, use the criteria found in this category in conjunction with the "Sanctions Program" search category above. To limit the scope of the enforcement action-related documents to those involving violations of discrete legal provisions (e.g. 560.204 of the ITSR), you can use the criteria in this category in conjunction with the search-by-legal provision option. We consider all enforcement actions to relate to the discrete legal provisions that have been explicitly cited in the enforcement action, or, in cases where OFAC has not specified the legal basis for penalty, the legal provisions that appear to have been violated. This is in addition to other provisions that appear pertinent to the enforcement action, e.g. certain interpretive or definitional provisions. The document types within the scope of these search criteria are those within the scope of the "Document Type" search criteria in the category titled "Documents Related to the Enforcement of Primary Sanctions Prohibitions."

For those interested in generating statistics concerning the proportion of OFAC-issued penalties that have certain characteristics--e.g. the proportion of penalties involving violations of the ITSR, etc.--note that some enforcement actions have only one document associated with them, while others have several. For example, some enforcement actions have associated with them OFAC settlement agreements, BIS settlement agreements and/or DOJ-issued deferred prosecution agreements, while some have only the basic OFAC "web post."

Therefore, for the purposes of generating statistics pertaining to OFAC civil penalties from 2006 onward, one should check only the "Enforcement Information Web Posts" box under the "Document Type" criteria. Doing so will provide the denominator for all of OFAC's civil penalties. Each discrete enforcement action is associated with one returnable item, even when multiple enforcement actions were announced on the same web post.

After checking the "Enforcement Information Web Posts" box under "Document Type," proceed to select other criteria, e.g. cases involving violations of the ITSR, which will provide your numerator.

For example, as of Feb. 2020, there were 362 total civil penalties, of which 178 involved violations of the ITSR. 49% of all penalties involved a violation of the ITSR. 42 (12% of the total) involved violations arising from a non-U.S. person "causing" a U.S. person to violate one or more primary sanctions prohibitions. 32 (9% of the total) involved violations arising from a non-U.S. person "causing" a U.S. person to violate one or more primary sanctions prohibitions of the ITSR.

Note that, other than one item included in the research system for illustrative purposes, the discrete number of total civil penalties excludes the dozens of penalties issued from 2006-2010 involving purchases of Cuban cigars by individuals. See Unnamed Individuals Fined for Purchasing Cuban Cigars (Penalty Extract Illustrative of Others Omitted From System) (2008). Altogether, there were 44 separate Cuban cigar-related enforcement actions pertaining to individuals from January, 2006 through March, 2019. For those wishing to calculate penalty statistics for all discrete violations, including the omitted Cuban cigar cases, add 43 enforcement actions to the total (the denominator). Note that all 44 discrete cigar-related enforcement actions were violations of 515.201 of the CACR and carried penalties in the range of $10,000 or less.

Notes:

i) While many of these search criteria are the product of the classification of violations on a purely objective basis where there is no room for argument, some entail judgment calls, particularly where OFAC has not connected the dots between a given violation and legal provision violated, and where the facts disclosed strongly suggest classification within a given search criterion, but where they are inconclusive. Where the facts provided are inconclusive as to the applicability of a given search criterion, we generally categorize documents as falling within the scope of criteria when it is highly likely that they apply, and discussion of the uncertain aspects of the classification is found in the comments section to any given returnable item.

ii) Where applicable, read the comments associated with the individual search criteria. Note that there is substantial overlap in the scope of the search criteria, as many types of violations are capable of being characterized several ways.

iii) For the purposes of these search criteria, the term "sanctioned person" includes all counterparties that are within the scope of prohibitions, whether or not blocked. For example, persons "ordinarily resident" in Iran are "sanctioned persons," even if they are not blocked and even if they are students studying outside of Iran (but still considered "ordinarily resident" in Iran for the purposes of, e.g. the export prohibition at 560.204 / 560.410).

iv) The factual characterizations of the violations come from the face of the web posts, additional information provided by related official documents, such as OFAC and/or BIS settlement agreements, and occasionally research into a company’s operations or news items related to a specific violation. When a given violation is associated with multiple documents (e.g. a web post and settlement agreement), the characterizations of the violation(s) are consistent across the documents, even when, for example, certain aspects of a violation are discernible from one document but not another. In all cases, where violations are categorized as within the scope of a given search criterion but the reason for this is not evident from the available official documents connected with the violation, the dots between the categorization and the violations are connected in the comments sections associated with the official documents. See e.g. Willbros USA, Inc. (2019), and comments thereto.

These search criteria cover instances of violations that were i) not alleged to be or otherwise evidently willful in nature, ii) where the alleged violator had at least some sort of a sanctions compliance program or otherwise made an attempt to comply with the laws alleged to have been violated. Whether or not such violations were of prohibitions that contain an explicit knowledge qualifier, OFAC considers violations within the scope of these search criteria to have occurred where the alleged violator knew or had a “reason to know” of relevant facts or circumstances underlying the violation(s). Relevant background reading: General Note on the Terms "Knowingly," "Should Have Known" And "Reason to Know" In the Primary Sanctions, Secondary Sanctions and Derivative Designation Contexts (System Ed. Note).

"Egregiousness" determinations were not always part of the enforcement guidelines. The first of the determinations appears in 2010.

For conglomerates and other multi-industry entities, these search criteria cover the industry in which a given actor was operating in connection with the corresponding violation.