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Case Nos. SDGT-572 and SDGT-574
[MAR 23 2006]
Jihad M Smaili, Esquire
Jihad M Smaili, Esq., L.L.C.
146 West 9th Street, Suite 330
Cleveland, OH 44113-1220
Dear Mr. Smaili
This responds to the matters raised in your letters of February 24, 2006, March 1, 2006 and March 9, 2006, on behalf of KindHearts for Charitable Humanitarian Development, Inc. ("KindHearts"), to the Office of Foreign Assets Control ("OFAC").
As you know, on February 19, 2006, the assets of KindHearts were Blocked Pending Investigation by OFAC pursuant to Executive Order 13224 of September 23, 2001 (66 FR 49079) and the Global Terrorism Sanctions Regulations, 31 C.F.R. Part 594 (the "GTSR"). Any and all property in which KindHearts has an interest, direct or indirect, that is or hereafter comes within the United States or the...
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1) Case Nos. SDGT-572 and SDGT-574 provide some notable interpretations of the GTSR blocking prohibition that are not immediately obvious from other statements on the public record as of 10/2021. Note that the letter pertained to a U.S. person charity that was a U.S. person and blocked pursuant to the GTSR.
2) “OVERSEAS OFFICES” AS “U.S. PERSONS” (IRRESPECTIVE OF LEGAL STATUS AS A "BRANCH")
In the outgoing letter to OFAC, counsel for the blocked person describes a “office in Palestine and a separately registered office in Lebanon (not really a branch).” OFAC treats both as “U.S. persons”, which provides that “The term United States person or U.S. person means any United States citizen, permanent resident alien, entity organized under the laws...