Rubin v. Islamic Republic of Iran 830 F.3d 470 (7th Cir. 2016), - OFAC/Treasury Amicus Brief

Date issued: Nov. 03 2014

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TURBOFAC Commentary (196 words)

Notes:

1) In TRIA case, the government/(OFAC Chief Counsel on brief) considered that property subject to the transfer directive of 535.215 does not become "blocked" pursuant to EO 13599/560.211 even if the Government of Iran could be said to have an interest in the property. EO 13599 explicitly carves out property subject to the IACR transfer directives of EO12281 and 535.215 [1]. The court ultimately agreed with the Government.

[1] "The prohibitions in section 1 of this order do not apply to property and interests in property of the Government of Iran that were blocked pursuant to Executive Order 12170 of November 14, 1979, and thereafter made subject to the transfer directives set forth in Executive Order 12281 of January 19, 1981, and implementing regulations...