Nov. 2014 Email from OFAC SC&E to Local Sudanese UNDP Staff in re: UNFCU Accounts

Date issued: Nov. 24 2014

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (911 words)

Notes:

1) The now-repealed SSR, as they existed as of 2014, are available here. Note that, at the time of the emails, Sudan was subject to a comprehensive IEEPA-based embargo.

The context of the inquiry to and reply from OFAC’s Sanctions Compliance & Evaluation unit was the United Nations Federal Credit Union having closed accounts for certain local Sudanese United Nations Development Programme (UNDP) staff members, citing OFAC regulations as the reason for the closure (see pp. 1-2 of native PDF file).

The United Nations Federal Credit Union, which was subject to an OFAC enforcement action in 2010, is a not-for-profit cooperative that, for OFAC purposes, is an ordinary “U.S. person.” According to the UN-produced letter at p. 5 of the native PDF file,...