Case No. BEL-2018-351645-1

Date issued: Oct. 03 2019

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TURBOFAC Commentary (181 words)

Notes:

1) Compare the guidance here with A Framework for OFAC Compliance Commitments (May 2, 2019). It is not clear why the applicant sought guidance considering that the individual at issue was not on the SDN list (possibly just a misunderstanding of the nature of the list-based Belarus Sanctions Regulations). In any event, the guidance is notable for the statement that "OFAC encourages a risk-based approach to OFAC compliance. Persons making an effort to comply with OFAC rules and regulations should conduct appropriate due diligence regarding the sanctions status of an individual or the ownership structure of a particular entity and evaluate the OFAC risks of a transaction before deciding whether to take an action." (Compare Case No. UKRAINE-EO13662-2014-314571-1, same language). It is noteworthy that OFAC emphasizes that what is expected is “appropriate due diligence regarding...