General Note Common to Most "Termination and acquisition of an interest in blocked property" Interpretive Provisions (System Ed. Note)

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TURBOFAC Commentary (2336 words)

Note Common to “Termination and acquisition of an interest in blocked property” Interpretive Provisions (System Ed. Note)

1) BACKGROUND

This provision appears in and is substantively identical across most sanctions programs in which asset blocking is a feature. Exceptions are the CACR, which refers to a GL for transfers by operation of law due to marital status changes; and the CACR and IACR not having been amended to explicitly include "attempt[s]" at transferring a property sufficient to establish an interest.

One should presume that OFAC interprets the CACR to block all property that would be blocked in light of any other "Termination and acquisition" interpretive provision. Note also that some versions of this provision include the construction “has or has had an interest,” which has been “retired”...