Notable "Derivative" Designations - Russia-Iran Oil Network Supporting the Assad Regime, Hizballah, and HAMAS

Date issued: Sep. 14 2018

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TURBOFAC Commentary (416 words)

Notes:

1) Refer to Introductory Note Common to all Derivative Designation Notices Included in the Research System (System Ed. Note). That note explains the specific criteria used for determining which designation notices are included.

2) NOTES SPECIFIC TO THIS DESIGNATION NOTICE

OFAC has characterized the activities described in the designation notice as "illicit," but is not clear whether the entirety of what is described is believed to violate international law or the laws of at least one country having jurisdiction over the transaction, or just some of it. In any event, the designation notice highlights how, in practice, the "material assistance" designation criterion can be used to capture "indirect assistance."

Sec 1(a)(i) of EO 13582 allows for the blocking of any person determined to:

"have materially assisted, sponsored, or provided financial, material, or technological support for, or...