Case No. MUL-2013-304318-1

Date issued: Jan. 13 2014

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TURBOFAC Commentary (2071 words)

Notes:

1) This guidance letter, indispensable on the subject of "indirect financing" (see generally General Note on “Indirect Financing,” or Investments in Third Country Companies that do Business with Sanctioned Parties), stands for a number of key propositions that accord with OFAC's general practice but are not, as of 9/2024, the subject of formal guidance that operates in an across-the-board fashion.

The applicant here is a non-U.S. person entity that operates "duty free" stores, some of which are located in comprehensively sanctioned jurisdictions. At the time the guidance request was made, each of Cuba, Iran, Syria and Sudan were comprehensively embargoed. In each case "new investment" in the relevant jurisdiction was prohibited, as was the provision of any service "to" the jurisdiction and the facilitation of a non-U.S. persons' new investment or provision of services to such jurisdiction.
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