FAC No. BEL-368210 (Notable Blocking Notices)

Date issued: Nov. 13 2007

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TURBOFAC Commentary (150 words)

Notes:

1) Compare FAC No. SDGT-197443, which also implicitly stands for the proposition that any "property of third parties in the possession or control of" a blocked person is property in which the blocked person has an "interest" (specifically, a possessory interest).

2) The blocking notice is notable for what appears to be the only instance (on file with us) of OFAC articulating a position that “act[ing] for or on behalf of” a blocked person is an activity that is necessarily within the scope of the basic blocking prohibition. In all likelihood, OFAC would consider "act[ing] for or on behalf of" a blocked person to implicate the prohibition, embedded within the basic blocking prohibition, against the provision of services to any blocked person.
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