Case No. Ukrnine-EO13662-2015-324517-1

Date issued: Apr. 16 2018

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TURBOFAC Commentary (336 words)

Notes:

1) Consistent with OFAC’s guidance clarifying the scope of SSI Directive 4, “a gas condensate field with a sea depth of ninety meters and location of 51 degrees north latitude and 143 degrees east longitude” is not a project that is subject to the prohibitions of the directive.

2) The application requests authorization for a non-U.S. company to “receive payment in U.S. dollars of approximately $221,432.00 from an unnamed party, with the applicant noting that it “plans to use a U.S. financial institution as an intermediary in converting the U.S. dollar payment received from [the unnamed party] into British Pounds”. Because the applicant’s bank must “use a U.S. financial institution as an intermediary in converting the U.S. dollar payment received…into British Pounds,” it is clear that the bank of the applicant is a non-U.S. bank that holds a dollar...