General Note on the Notion of Being an "Agent" of an FTO for the Purposes of the FTOSR; the De Facto Relationship of that Determination to the Scope of the GTSR (System Ed. Note)

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TURBOFAC Commentary (1638 words)

General Note on the Notion of Being an "Agent" of an FTO for the Purposes of the FTOSR; the De Facto Relationship of that Determination to the Scope of the GTSR (System Ed. Note)

All entities carrying the [FTO] program tag on the SDN list also have the [SDGT] program tag, meaning that they are subject to the Global Terrorism Sanctions Regulations (GTSR). The GTSR prohibit certain transactions involving property in which SDGTs "have an interest" (594.201), and the FTOSR, which applies only to U.S. financial institutions, generally does the same with respect to funds in which FTOs have an interest, but unlike the GTSR, the FTOSR also applies on its face to all transactions of "Agents" of FTOs, where "Agent" is...