Case No. ZI-362

Date issued: Aug. 12 2010

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (611 words)

Notes:

This is one of the rare guidance documents addressing the question of a producer's potential ongoing "interest" in goods that it has produced.

1) "Has or has had an interest"

The version of 541.406 of the ZSR that was interpreted in this letter provided as follows:

§ 541.406 Offshore transactions.
The prohibitions in § 541.201 on transactions involving blocked property apply to transactions by any U.S. person in a location outside the United States with respect to property that the U.S. person knows, or has reason to know, is held in the name of a person whose property or interests in property are blocked pursuant to § 541.201(a) or in which the U.S. person knows, or has reason to know, a person whose property or interests in property are blocked pursuant to § 541.201(a)
has or has had an interest...