Case No. IA-2017-340699-1 [Application Included in Original PDF]

Date issued: Apr. 03 2017

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TURBOFAC Commentary (668 words)

Notes:

1) See p. 9 of the native PDF file for Case No. IA-2017-340699-1, and p. 7 for the associated blocking memorandum. Read in conjunction with the criminal charging information at p. 13 et seq. of the native PDF file. Assuming that the facts laid out in that document were the facts as OFAC understood them at the time of the blocking notice and license denial, the case is notable as an unusual example of the blocking prohibition being applied to a funds transfer. Here, the U.S. person recipient of the blocked payments had allegedly:

“brokered, negotiated, and facilitated the sale of computer servers with U.S. Company #1, accepted payment from [the Hong Kong company of Iranian] unindicted coconspirator #2 for the computer servers, paid U.S. Company #1 for the computer servers, and intended to take possession of the computer servers and ship them...