Foreign Assets Control Regulations for Exporters & Importers (2012 version)

Date issued: Jan. 24 2012

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TURBOFAC Commentary (395 words)

Notes:

1) This document remains of OFAC's website as of 5/2019, but largely out of date, referencing certain programs that no longer exist and pre-dating many of the trickier, new programs such as Russia SSI, Venezuela and secondary sanctions generally.

2) Three statements from the document are worth noting, and to not seem to appear anywhere else on OFAC’s website except in similar overview documents. The rest of the document generally restates the basics of certain sanctions programs without providing interpretive guidance beyond what is evident from the face of the regulations themselves.

a) "Property": With respect to the boilerplate definition of "property" in the regulations, OFAC states that "[p]ractically everything that banks do every day involves 'property' within the meaning of the regulations." This characterization accords with the weight of OFAC's practice, but it is notable to see OFAC phrase...