General Note Common to All "Transfer" Definitional Provisions, and the Meaning of "Transferred, Paid, Exported, Withdrawn, or Otherwise Dealt in" (System Ed. Note)

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TURBOFAC Commentary (2090 words)

General Note Common to All "Transfer" Definitional Provisions, and the Meaning of "Transferred, Paid, Exported, Withdrawn, or Otherwise Dealt in" (System Ed. Note)

1) BACKGROUND

With two unimportant exceptions, this definition of "transfer" is uniform across all sanctions programs of which the blocking of property is a feature. As it relates to actions (within the U.S. or otherwise) that may or may not be taken with respect to property subject to the basic blocking regulation, note that the context of the term "transfer," which is itself defined about as broadly as possible, is the statement that property subject to blocking prohibitions may not be "transferred, paid, exported, withdrawn, or otherwise dealt in". Between "transfer" being defined as broadly as it is, and "otherwise dealt in" not being defined at all, the plain English translation of these terms amounts roughly to "do anything with respect...