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Case No. Ukraine2-2014-311316-1
Michael Faucette, Esq.
Mark Barnes & Associates
1350 I Street NW, Suite 260
Washington, D.C. 20005
Dear Mr. Faucette:
This is in response to a request of July 18, 2014 as supplemented on July 28, 2014, July 29, 2014, July 30, 2014, August 1, 2014, and October 22, 2014 (collectively, the "Application"), on behalf of RWC Group LLC (RWC), a company based in Tullytown, Pennsylvania, to the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), for authorization to sell and ship [ ] (the "Cargo") obtained from Kalashnikov Concern (KC), an entity whose property and interests in property are blocked pursuant to the Ukraine-Related Sanctions Regulations, 31 C.F.R. Part 589 and Executive Order 13661 of March 16, 2014. "Blocking Property of Additional Persons Contributing to the Situation in Ukraine" ("E.O. 13661"), to...
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1) BACKGROUND
On 07/16/2014, Kalashnikov Concern (KC) was blocked pursuant to EO 13661. That same day, OFAC sent a Notification of Third Party Blocking to the president of RWC Group, LLC (RWC) informing that "importing any goods in which [KC] has an interest or engaging in any financial or commercial transaction with the Designated Party is prohibited," and that "further performance under any contracts or written agreements, or in connection with any transactions under way, between RWC Group, LLC, and the Designated Party, including as a representative or agent thereof, is prohibited".
Two days later, RWC, the "exclusive U.S. importer of products from KC," applied for a license to "take delivery and distribute into U.S. commerce" certain KC goods (pdf, p. 6) that were "in transit to the United States" at the time of the application (pdf, p....