Civil Enforcement Information - Toyota Motor Credit Corporation

Date issued: Apr. 25 2013

TURBOFAC Commentary (116 words)

Notes:

1) The general blocking provisions of 598.203 apply to "services performed by U.S. persons, wherever located: (1) On behalf of or for the benefit of a specially designated narcotics trafficker; or (2) With respect to property interests of a specially designated narcotics trafficker." [598.406]

2) Refer to Wells Fargo Bank, N.A. (2nd action) (2013), dealing with one of the same SDNs. It seems likely that TMCC was caught by OFAC in connection with its pending investigation of Wells Fargo.

3) Note to "maintain" an account for an SDN is technically a violation a blocking prohibition, even if no actual transactions are processed with respect to the account (hence the description "maintained a loan account for").