Enforcement Release: Family International Realty LLC and its Owner

Date issued: Jan. 16 2025

Last substantive commentary amendment:
Jan. 24 2025

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TURBOFAC Commentary (984 words)

Notes:

1) From a legal basis standpoint, the activities described in the Enforcement Release are clear violations as (i) dealings in (including an unlicensed “transfer” of) “blocked property,” i.e. the real estate located within the U.S. in which the blocked person had an interest, (ii) the provision of services to the blocked owners of the properties, and (iii) the receipt of funds from the blocked owners of the properties. OFAC refers to “U.S. Person-1’s resolution of criminal charges with the Department of Justice related to a subset of the apparent violations” (see https://storage.courtlistener.com/recap/gov.uscourts.flsd.679897/gov.uscourts.flsd.679897.1.0.pdf for further information).

2) The enforcement action makes clear that property “jointly” owned by an SDN and spouse is blocked property (be it bank accounts or real estate).

3) OFAC alleges a “scheme…to transfer nominal ownership of [SDN]...