Ministry of Def. & Support for the Armed Forces of the Islamic Republic of Iran v. Cubic Def. Sys., Inc. 665 F.3d 1091 (9th Cir. 2011) - OFAC/Treasury Amicus Brief

Date issued: May. 04 2011

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TURBOFAC Commentary (632 words)

Notes:

1) This case illustrates how when a given fact pattern touches on multiple sanctions programs, each must be analyzed separately. GLs applicable in one program have no bearing on whether a transaction may be permitted pursuant to a different program.

2) A judgment entered prior to a party being blocked is not retroactively prohibited by the subsequent blocking of a party, but the judgment itself becomes blocked as of the date of the blocking of the party, and all acts taken with regard to the judgment are subject to the applicable sanctions regulations.

3) District court confirmation of arbitral awards is within the scope of 560.525(a)(5)(i) of the ITSR, as well as the WMDPSR (544.507).

The...