Civil Enforcement Information - CSE Global Limited and CSE TransTel Pte. Ltd.

Date issued: Jul. 27 2017

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TURBOFAC Commentary (780 words)

Notes:

1) For further factual information see Settlement Agreement - CSE Global Limited and CSE TransTel Pte. Ltd. (2017).

2) This is the first time in which OFAC actually articulates, in an enforcement action web post, that its basis for penalizing non-U.S. persons acting outside of OFAC's jurisdiction is the territorially limitless prohibition against "causing" violations (contained in IEEPA and, in the case of the ITSR, 560.203).

Typically, OFAC only charges a violation of the substantive regulatory provision violated. Here, however, OFAC takes the more disciplined approach and articulates that the actual violation is of 560.203 (causing a violation), and that the relevance of 560.204 to the finding of a violation is not that it was directly violated, but...