PRINT
DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220
Case No. ZI-362
Mr. Martin Rapaport
Chairman
Rapaport Group
133 East Warm Springs Rd, Suite 100
Las Vegas, NV 89119
Dear Mr. Rapaport:
This responds to your letter dated June 30, 2010, on behalf of Rapaport U.S.A., a US. company which you explain "provides added-value services for the diamond industry." You request guidance on the applicability of authorities administered by the Office of Foreign Assets Control ("OFAC") to the purchase by a U.S. person of diamonds from certain companies located in Zimbabwe and/or their investors. First, you advise that Mbada Diamond Mining (alternatively Condurango), Zimbabwe ("Mbada"), is reportedly owned by Robert Mhlanga; the Zimbabwe Mining Development Corporation; and Grandwell Holdings, Mauritius, which is owned by New Reclamation Group Pty Ltd Reclam, South Africa. Second,...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
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...