Case No. MUL-2018-357305-1

Date issued: Feb. 26 2019

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TURBOFAC Commentary (683 words)

Notes:

1) Cambridge Mercantile Corp. (U.S.A.) operates “Corpay,” which is an accounts payable system used by companies to process cross-border payments. Here, Cambridge Mercantile Corp. says that it “received an invoice from the U.S. law firm” (presumably for processing) where the payment was in connection with “legal services performed on behalf of” and SDN (i.e. something in connection with proceeding taking place in a U.S. District Court). OFAC recounts that “the invoice instructs payment be made to a Russian law firm” that has a bank account at a (presumably Russian) bank subject to the new debt prohibitions of SSI Directive 1. The SDN was blocked pursuant to the URSR and Cyber regulations, both containing standard legal services GLs at 589.506(a) and 578.506(a).

OFAC says “[a]ssuming that the...