FNKSR - General License 4G - Authorizing Certain Transactions Involving the Panamanian Mall and Associated Complex, Soho Panama, S.A. (a.k.a. Soho Mall Panama)  (Expired on June 15, 2017)

Date issued: Apr. 27 2017

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (681 words)

Notes:

1) Expired GL included in OFAC's "Archive of Revoked and Expired General Licenses."

2) Refer to OFAC FAQ # 472 (Removed) - General Licenses Issued Authorizing Certain Activities Pertaining to Panama.

3) While expired, this GL has continued cross-programmatic interpretive value concerning the notion of a blocked person having an "interest" in property.

Here, the license pertains to a blocked SDN mall operator/complex, as well as "non-designated individuals or entities located in the designated [] mall and associated complex." These include individual stores within the mall complex, many of which were large international brands. The GL gives no reason to believe or suspect that this entire class of non-designated entities consists of entities blocked pursuant to the 50% rule for being owned by the...