Case No. Ukraine2-2014-311316-1 [Application included]

Date issued: Nov. 04 2014

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TURBOFAC Commentary (1199 words)

Notes:

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....