ENF 23477 (Notable Notification of Blocking)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (235 words)

Notes:

1) As described at pp. 52 et seq. of the native PDF file, the "Ellissa Holding" and related entities were engaged in the exportation of cars from the U.S. to Africa, evidently even after Elissa was made an SDN. U.S. person entities associated with Elissa would purchase cars in the U.S. and export them.

2) The notification regarding blocked property appears to be aimed at various U.S. person entities associated with the exportation of cars that were seized at port by CBP and physically blocked by OFAC.

3) The blocking notification is notable for the procedural mechanism by which OFAC sought to mitigate the burdens of physical blocked property having been detained at customs. OFAC authorized the release of the vehicles from detention, and appears to have opened accounts at two banks...

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ENF 23477 (Notable Notification of Blocking)

TURBOFAC Commentary (235 words)