OFAC FAQ (Current) # 368 - Executive Order 13664, "Blocking Property of Certain Persons with Respect to South Sudan

Date issued: Jun. 02 2014

Last substantive commentary amendment:
Apr. 03 2024

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TURBOFAC Commentary (416 words)

Notes:

1) See NGO-Humanitarian Guidance, where OFAC makes the same statement concerning dealings with entities controlled by SDNs but not otherwise blocked.

2) See FAQ 398 and comment thereto for clarification of this concept in an explicitly cross-programmatic manner. OFAC interprets all regulations and executive orders to which the 50% rule applies such that blocking by operation of law is done only with respect to ownership interests, whereas either ownership or control can result in OFAC making an affirmative determination to designate an entity. See also OFAC SpaceX Litigation Correspondence (2014); General Note on the Distinction Between Blocked Person "Control" Over Property and "Control" over the Assets of a Company Controlled by a Blocked Person.

3) OFAC uses the language "profiting from" to describe what it apparently would consider to be an "indirect" dealing with an...