License No. FNK-532a

Date issued: Aug. 07 2009

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 (415 words)

Notes:

1) The specific license referenced in the guidance was issued to a U.S. person distributor of goods produced by a blocked person, at a time when OFAC interpreted the blocking regulation such that all goods in which an SDN "had" an interest were subject to the prohibition, thereby making it so goods produced by blocked persons were necessarily subject to the blocking prohibition even if sold free and clear in a third country outside of OFAC’s jurisdiction (compare Case No. ZI-362, and note that this policy changed in our around 2012). The SL at issue here was issued pursuant to a licensing policy similar to the one codified at 598.207 (“[p]roperty blocked pursuant to § 598.202 may, in the discretion of OFAC, be sold or liquidated and the net proceeds placed in...