Case Nos. SDGT-572 and SDGT-574; License No. SDGT-572 [Application included]

Date issued: Mar. 23 2006

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TURBOFAC Commentary (530 words)

Notes:

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...