Enforcement Release - Amazon.com, Inc.

Date issued: Jul. 08 2020

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TURBOFAC Commentary (784 words)

Notes:

1) BASES FOR LIABILITY

a) The "Service" Export Prohibitions (Non-blocked Persons)

OFAC alleges violations of the Crimea, Iran and Syria embargoes in connection with the provision of goods and/or services "to persons located in the sanctioned region or countries of Crimea, Iran, and Syria." These are presumably all violations of the broad prohibition on the provision of services (and/or goods except in the case of Syria) to persons "in" or "ordinarily resident in" a given sanctioned destination. In this case, OFAC made no mention of the "ordinarily resident" standard, suggesting that the IP and/or physical addresses of the persons at issue were the basis on which to conclude that the recipient of the services was "in" a sanctioned destination. Compare Civil Enforcement Information - Standard Chartered Bank (Second Global Settlement).

b) The Reporting Requirement in