Case No. NPW-2014-308526-1

Date issued: Nov. 14 2014

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TURBOFAC Commentary (698 words)

Consolidated Comment on Case No. NPW-2014-308526-1 and Deutsche Forfait Terms of Removal Agreement

1) BACKGROUND / SDN LIST REMOVAL

On February 6, 2014 OFAC designated DF Deutsche Forfait AG, a German provider of trade financing, its U.S. subsidiary and board member Ulrich Wippermann, was designated pursuant to EO 13382 (WMDPSR) for having “facilitated oil deals in circumvention of oil sanctions for NIOC, an entity determined to be an agent or affiliate of the IRGC and designated under E.O. 13382.” See https://home.treasury.gov/news/press-releases/jl2287. More specifically, the company was in the business of “forfaiting,” i.e. purchasing receivables such as letters credit from exporters and discounting the receivables without recourse. (See https://www.trade.gov/forfaiting).

On October 16, 2014, just 249 days after the initial designation, the entities...