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Case No. BU-2330-1
[***]
Grand Circle LLC
347 Congress Street
Boston, MA 02210
Dear Mr. [***]:
This is in response to your letter dated December 23 , 2010, on behalf of Grand Circle LLC (“GCL”), to the Office of Foreign Assets Control (“OFAC”). You request a license authorizing GCL to remit [***] to [***] during the period of September 15, 2010, through October 29, 2010. You represent that [***] may be owned or controlled by the Htoo Trading Company Limited, an entity whose property and interests in property are blocked pursuant to Executive Order 13448 of October 18, 2007. You also represent that on October 12, 2010, GCL attempted to wire a payment of [***] to [***] for transactions incident to travel and that this payment was blocked by [***]
Except as otherwise authorized, the...
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1) At the time this guidance letter was issued, EO 13448 was not incorporated in any set of sanctions regulations (it was implemented in the BSR at 79 FR 37108, June 30, 2014). The license request deals with a blocked payment made by a U.S. person tour service provider in connection with “transactions incident to travel”. An entity assumed to be blocked pursuant to the 50% Rule had an interest in the payment (likely a hotel or an airline). OFAC determines that the prohibition on the provision of financial services and the relevant blocking prohibition in the unincorporated EO applied to the transaction. This is one of many examples of OFAC acknowledging that the IEEPA travel exemption applies in the context of...