Date issued: Jan. 31 2019
Last substantive commentary amendment:
May. 08 2023
You've hit a wall.
Sign in if you have an account,
learn more about TURBOFAC and subscription options, or
purchase access
to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.
Note: this FAQ and comments thereto were posted/written prior to the blocking of the Government of Venezuela pursuant to EO 13884. Neither the FAQ nor the comment have been updated in light of that development.
1) This FAQ is ostensibly about Venezuela, but with obvious cross-programmatic application for all programs operating within the rubric of standard blocking language.
OFAC impliedly makes two statements about the scope of the term "interest," as it relates to "property" in which a blocked person has an "interest."
First, a blocked person has an "interest" in any debt, equity, or other holdings issued or owned by that person, even if such debt is held by a third-party fund.
Second, just because a blocked person's blocked debt is part of a fund, it does not render the entire fund "property" in which...