General Note on the 300-level definition of "Blocked account; blocked property"; Relation to "Possession or Control" Concept (System Ed. Note)

Last substantive commentary amendment:
Oct. 15 2024

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TURBOFAC Commentary (2282 words)

General Note on the 300-level definition of ‘Blocked account; blocked property’ (System Ed. Note)

1) As a Quasi-Interpretive Provision Extending Prohibitions to Property "in Which" Blocked Persons Have an "Interest"

With the exception of the handful of sanctions regulations that are not centered around the blocking of property [1], this definitional provision features in every sanctions regulation and unless noted otherwise is substantively identical across programs.

Crucially, in the vast majority of programs [2], it is the place in the entire set of regulations explicitly stating that "blocked property" includes not only "property and property interests of" blocked parties [3] but also "property and property interests" "in which" such person "has an interest"[4].

The distinction between these two concepts, "property of" a person and "property in which [a person] has an interest," is of crucial importance for appreciating the scope of...