Civil Enforcement Information - Aero Systems Engineering

Date issued: Sep. 01 2006

TURBOFAC Commentary (98 words)

Notes:

1) Violation of now-repealed, full-scale version of the Libyan embargo. The bank at issue was blocked as meeting the definition of the Government of Libya.[1] A customer attempting to send funds to a blocked bank, even where the bank is not a party to an underlying transaction, considered to constitute dealing in property in which the blocked bank has an interest.

[1] See § 550.209 -Prohibited transactions involving property in which the Government of Libya has an interest; transactions with respect to securities (https://www.govinfo.gov/content/pkg/CFR-2002-title31-vol2/xml/CFR-2002-title31-vol2.xml).