Case No. BU-2330-1

Date issued: Dec. 11 2013

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TURBOFAC Commentary (308 words)

Notes:

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...