Case No. Ukraine-EO13662-2018-353695-1

Date issued: Jun. 18 2018

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TURBOFAC Commentary (673 words)

Notes:

1) The 2018 FIFA World Cup (soccer) was held in Russia, and a number of the key host city airports were "managed and/or operated by Russian entities, specifically Basel Aero and Airports of Regions, that are 50 percent or more owned by Basic Element or the Renova Group, entities". See https://en.wikipedia.org/wiki/Airports_of_Regions and https://en.wikipedia.org/wiki/Sochi_International_Airport.

The applicant non-US person airline was seeking guidance on the sanctionability and/or prohibited nature of "pay[ing] landing fees and ground handling payments to the SDN-Related Airports in Euros or Rubles in the approximate equivalent amount of USD 3,500 with an estimated total payments of under USD 30,000". The applicant appears to have represented that the transaction would have no U.S. nexus ("no U.S. financial institutions will be involved in the transactions and no SAS employee or contractor operating on the charter...