Case No. GN-2016-326569-1

Date issued: Jun. 13 2013

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 (108 words)

Notes:

1) Unusual guidance letter (note four-year time between application and response) highlighting OFAC’s unwillingness to give entities and vessels “clean bills of health” in the way requested by the applicants. When presented with specific facts, OFAC will opine on whether such facts have sanctions implications (see e.g. Case No. UKRAINE-EO13662-2014-314571-1), but not go much further than that. In OFAC’s response, OFAC does not foreclose the possibility that the vessel at issue is “blocked property” (e.g. because a blocked person has an interest therein) even though the entities associated with the vessel and the vessel itself did not appear on the SDN List.