Case No. SY-2019-363541-1

Date issued: Oct. 09 2019

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TURBOFAC Commentary (155 words)

Notes:

1) On June 11, 2019, OFAC designated the “Four Seasons Damascus,” a Syrian entity that was evidently managed by the Canadian [1] “Four Seasons Hotels Limited” (“FSHL”) pursuant to a management agreement. According to the guidance letter, FSHL corresponded with OFAC on June 20, 2019 to inform OFAC that FSHL “terminated management of the ‘Four Seasons Damascus’ effective June 19, 2019”. The purpose of this guidance letter appears to be to assuage concerns of any counterparties of FSHL that the designation of Four Seasons Damascus would not impact dealings between FSHL and third parties. OFAC confirms that U.S. persons could deal freely with FSHL, so long as the dealings do not involve any blocked persons. (Query: where would the travel exemption come into play as it relates to an SDN hotel where the blocking occurs pursuant to an