PRINT
[FULL TEXT IN NATIVE PDF FILE]
FOREIGN ASSETS CONTROL REGULATIONS FOR IMPORTERS AND EXPORTERS
...
[p.3]
V. Terminology...
...F——Property [Generally]
Anything of value. Examples of property include: money, checks, drafts, debts, obligations, notes, warehouse receipts, bills of sale, evidences of title, negotiable instruments, trade acceptance, contracts, and anything else real, personal, or mixed, tangible or intangible, "or interest or interests therein, present, future, or contingent." Practically everything that banks do every day involves "property" within the meaning of the regulations. Likewise, "property interest" is defined as any interest whatsoever, direct or indirect.
...
[p.8]
VII...
...A. Transactions involving property in which Cuba or a Cuban national has an interest
The Regulations prohibit any person subject to U.S. jurisdiction from dealing in any property in which Cuba or a Cuban national has or has had any interest. Under the Regulations, "property" is very broadly defined...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
1) This document remains of OFAC's website as of 5/2019, but largely out of date, referencing certain programs that no longer exist and pre-dating many of the trickier, new programs such as Russia SSI, Venezuela and secondary sanctions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...