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Case Nos. CU-77330, CU-77408, CU-77427 and CU-77518, and FAC No. CU-406608
[ ], Esq.
[ ]
2555 Pennsylvania Ave., NW
Suite 1005
Washington, DC 20037
Dear Mr. [ ]:
This is in response to your letters of November 21, 2007, December 31, 2007, January 2, 2008, and February 18, 2008, on behalf of your client the United Nations Federal Credit Union ("UNFCU"), to the Office of Foreign Assets Control ("OFAC"), requesting the extension of License No. CU-75839 which authorized UNFCU to close accounts held by Cuban employees of the United Nations and affiliates of said employees, or the closure of individual Cuban accounts at UNFCU, and to transfer the funds to one or more third parties that are not persons subject to U.S. jurisdiction. In addition, you wrote a letter dated April 16, 2008 (CU-406608),...
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1) See Civil Enforcement Information - United Nations Federal Credit Union, and query whether the violations at issue in that case were the "certain unauthorized financial transactions" described in this letter (note that OFAC would normally not provide voluntary disclosure credit for violations disclosed in the context of a letter to the licensing division).
2) At the time of this letter and prior, there was no "official business" GL covering UN-related transactions. See 515.562(b) (2015), Nov. 2014 Email from OFAC SC&E to Local Sudanese UNDP Staff in re: UNFCU Accounts, and query whether the transactions licensed here may qualify for the "official business" exemption if engaged in today.
3) Apart from the old licensing policy discernible from the letter, OFAC provides guidance of some potential relevance today, suggests that...