Case No. CU-76349

Date issued: Mar. 02 2007

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TURBOFAC Commentary (803 words)

Notes:

1) BACKGROUND

Case No. CU-76349 arises from a Cuban national ("Gainza") having opened an account at a Citibank branch in Miami, using his U.S. citizen niece’s ("Lugo") Miami address, while he was still resident in Cuba (p. 6-7 and 21, PDF). (Gainza was not an "unblocked national" within the meaning of 515.505).

On February 2, 2001, Gainza executed a Change of Ownership form to hold all funds in the Account “in trust for” Plaintiff (p. 25). "In or around April 2002, Citibank became aware of Mr. Gainza’s status as a resident of Cuba and advised him (via correspondence sent to Plaintiff’s residence) that the Account would be blocked pursuant to federal regulations that required financial institutions to block the accounts of Cuban nationals." (P. 21).

On April 26, 2006, Gainza submitted an unblocking application to OFAC (pp. 2-3) explaining that the...