Case No. UKRAINE-EO13685-2018-358212-1

Date issued: May. 24 2019

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (79 words)

Notes:

1) This is a critical guidance letter as it relates to OFAC’s interpretation of its general embargo regulations in the context of U.S. person dealings in funds that derive from, or are linked to, activities that would be prohibited for U.S. persons to engage in (e.g. the sale of real estate in Crimea). For further discussion, see relevant portions of General Note on U.S. Person Dealings in Funds or Proceeds Linked to Sanctions-implicating Transactions (System Ed. Note).