July, 2015 letter to OFAC from the Clearing House Association L.L.C., and the Bankers Association of Finance and Trade re: Blocked Burmese Port

Date issued: Jul. 17 2015

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TURBOFAC Commentary (60 words)

Notes:

1) The correspondents report that OFAC provided guidance to the effect that ports blocked by operation of law as a result of ownership by SDNs were considered to have an "interest" in trade documentation involving shipments that departed from the blocked port. Contrast BAFT/ The Clearing House: Guiding Principles for Sanctions Issues Related to Shipping and Financial Products (2017).