United States v. Griffith (1:20-cr-00015) (2021); OFAC "Licensing Determination"

Date issued: Nov. 21 2019

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TURBOFAC Commentary (1438 words)

Notes:

1) Page 1 of the native .pdf file contains the indictment, filed on 11/21/19, against Virgil Griffith for alleged violations of the NKSR. Two days prior, an attorney at the DOJ submitted a formal request to OFAC for a determination as to whether Griffith violated the NKSR.

The facts, from the perspective of the government and as presented to OFAC, are laid out in the “License Determination” request.

Note that this appears to be the first OFAC and/or DOJ enforcement action of primary sanctions prohibitions that arise from participation by a U.S. person in a conference organized and attended by sanctioned persons.

2) THE INFORMATIONAL MATERIALS EXEMPTION; EXPORTATION OF SERVICES


In the email dated 11/21/2019, OFAC’s Chief Counsel responds to the “License Determination” request by saying that “the...