Case No. UKRAINE-EO13662-2015-323301-1

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (829 words)

Notes:

1) BACKGROUND

At the time the application was made and the guidance letter was issued, Helsinki Halli Oy "own[ed] and operate[d] Hartwall Arena" (see letter). Helsinki Halli Oy was widely reported as being ~45 percent owned by a holding company (Arena Events) that was "50 percent owned by Langvik Capital, a Finland-based investment company owned by 'the Rotenberg family, and 50 percent owned by a Luxembourg-based company owned by [Gennady] Timchenko." At the relevant times, Timchenko was an , and the two 25% "Rotenberg" owners, i.e. Boris and Arkady Rotenberg, were also both SDNS. (See e.g. May 10, 2014 article at https://www.rferl.org/amp/sanctions-american-companies-jittery-russian-business-ties-us/25380189.html). Meanwhile, as discussed in the guidance letter, OFAC's 50% rule applied to any entity "in which such blocked persons own, whether individually or in the aggregate, directly or indirectly, a 50 percent or...

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Case No. UKRAINE-EO13662-2015-323301-1

TURBOFAC Commentary (829 words)