OFAC Enforcement - Southern Cross Aviation, LLC

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (938 words)

Notes:

1) This is one of two Findings of Violation to be announced on the same day (see also Southern Cross Aviation, LLC (2019)).

Compare Visa International Service Association (2013) and MasterCard International Incorporated (2016); two other FOV notices issued where the violation announced was only of the . Thus far, OFAC appears to have never issued a monetary penalty or FOV notice for a violation of the RRPR where the RPPR violation was not accompanied by one or more substantive (rather than procedural) sanctions violations. Here there was an accompanying substantive violation, but it only resulted in a cautionary letter, which ordinarily would not be made public.

This case is fairly straightforward insofar as 501.602 provides that every person is "required to furnish...complete information relative" to transactions within the scope of the RPPR, and there...

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Civil Enforcement Information (FOV) - Southern Cross Aviation, LLC

TURBOFAC Commentary (938 words)