Office of Global Targeting PPT Presentation (Internal)

Date issued: Apr. 19 2016

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.

TURBOFAC Commentary (420 words)

Notes:


1) This presentation, which dates from around mid-2016 (see p. 11), appears to have been internal to OFAC prior to it being released (see p. 24). The presentation contains some notable insights concerning the designation process and its effects. Some of these statements are obvious, but unusual to see in the context of a document prepared by OFAC.


This includes (i) the sources of information portion of pp. 7 and 8, and (ii) the "may conduct outreach to effect a change" statement at p. 9, the (iii) "Additional Effects of Sanctions" slide at p. 17 acknowledging that designations "[m]ake it difficult for targets to continue any modern financial activity, even with foreign banks".


The presentation also provides some notable interpretations of the standard derivative designation criteria.


2) ACTING ON BEHALF OF


Notable for the statement that "'Acting for or on behalf of' can be interpreted to apply in many...