Case No. NPW-2014-310859-1

Date issued: Nov. 27 2015

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TURBOFAC Commentary (92 words)

Notes:

1) See Case No. NPW-2014-308526-1 and Deutsche Forfait Terms of Removal Agreement. Query whether, even if Deutsche Forfait were still blocked as of the time of the proposed transaction, a payment would involving U.S. persons would have been prohibited (or whether Deutsche Forfait’s claim assignment (presumably outside of U.S. jurisdiction) would have extinguished Deutsche Forfait’s interest in any subsequent payment to satisfy the third-party debt. OFAC is agnostic on the question of whether the proposed transaction would have required a license if Deutsche Forfait were still blocked.