Statement on the Seizure of Seguros Continental S.A. by the Government of Honduras

Date issued: Oct. 22 2015

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TURBOFAC Commentary (495 words)

Notes:

1) Consolidated comment on Statement on the Seizure of Seguros Continental S.A. by the Government of Honduras; Statement on Proposed Liquidation of Banco Continental; Statement on the Felix Maduro Group.

These three OFAC "statements" all perform the same function, which is to assure non-U.S. persons not otherwise subject to the prohibitions of the FNKSR that dealings with the entities at issue will not be determined to constitute "[m]aterially assisting in, or providing financial or technological support for or to, or providing goods or services in support of, the international narcotics trafficking activities of a specially designated narcotics trafficker."

598.314 of the FNKSR provides for the possibility of designation upon a "material assistance" determination, which OFAC has stated may be based upon ordinary commercial dealings between parties...