Civil Enforcement Information - American Bankers Life Assurance Company of Florida

Date issued: Jun. 06 2007

TURBOFAC Commentary (91 words)

Notes:

Compare Civil Enforcement Information - An Unnamed Individual (1) (2007).

The provision of funds to a blocked person is prohibited by the standard blocking language even where this is not made explicit, as is the case with respect to the NTSR. In this case, OFAC could have also considered the actions to constitute the provision of services to an NTSR (536.406). It is impermissible to perform services "[w]ith respect to property interests of a specially designated narcotics trafficker," even if those services are not performed on behalf of the blocked person.