Enforcement Proceeding Correspondence - Finding of Violation Notice - B Whale Corporation, a Member of the TMT Group of Shipping Companies (2014, not published)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (535 words)

Notes:

1) For consolidated comment on the case see Civil Enforcement Information (FOV) - B Whale Corporation, a Member of the TMT Group of Shipping Companies.

2) This FOV notice was sent three years prior to the version made public. What follows is an excerpt from a bankruptcy court filing explaining the chronology of the enforcement process. Note that the narrative paragraph of the two FOV notices is subtly different, with the 2017 version specifying that the ship to ship transfer took place "off the coast of Iran" and that the involved was an SDN "at the time the transaction occurred." These specifications were apparently made by OFAC in response to legal arguments fighting the penalty. It may be that the 560.201 violation depended on the Iranian ship being close enough to the coast of Iran that the locations of...

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Finding of Violation Notice - B Whale Corporation, a Member of the TMT Group of Shipping Companies (2014, not published)

TURBOFAC Commentary (535 words)