Notable Examples of Activities that Constitute a "Transfer" of or "Dealing in" Property in Which a Blocked Person has an "Interest" (System Ed. Note)

Last substantive commentary amendment:
Nov. 04 2024

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TURBOFAC Commentary (4933 words)

Notable Examples of Activities that Constitute a "Transfer" of or "Dealing in" Property in Which a Blocked Person has an "Interest"

Activities that Constitute a "Transfer" of or "Dealing in" Property in Which a Blocked Person has an "Interest" – Notable Examples in the Context of Any Property Within the Possession or Control of a U.S. Person

1) "[T]ransfer of funds or credit by a U.S. financial institution between blocked accounts in its branches or offices is authorized, provided that no transfer is made from an account within the United States to an account held outside the United States, and further provided that a transfer from a blocked account may be made only to another blocked account held in the same name." The implication is that this is within the scope of the basic blocking regulation as a "transfer" or "dealing"...