Notable "Derivative" Designations - PB Tankers S.P.A. (Italy)

Date issued: Apr. 12 2019

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TURBOFAC Commentary (1233 words)

Notes:

1) For the criteria we use to determine what designation notices to include in the Research System, see Introductory Note Common to all Derivative Designation Notices Included in the Research System.

2) This is a rare, notable designation notice for the following reasons.

First, it is one of the few that sanction persons for engaging in international trade transactions that meet the criteria detailed in the "Introductory Note" referenced above [1]. Those criteria, when met, indicate that derivative designation authorities are being used as "quasi secondary sanctions," even where, as here, there were theoretically no "secondary sanctions" on Venezuela at the time of the designation.

Second, the designation is a rare use of a primary sanctions designation authority to designate a person for "operating in" a given sector of a targeted economy as a result of an international trade transaction...