31 CFR § 515.311 - Property; property interests.

Date issued: Jul. 18 1996

TURBOFAC Commentary (168 words)

Notes:

1) This provision controls the scope of the basic blocking regulation, and is common to all sanctions regulations involving the blocking of property. It is substantively boilerplate in all sanctions programs, except for slight variations in the CACR and IACR. Refer generally to Note Common to all "Property; property interest" Definitional Provisions (System Ed. Note).

Differences between the CACR and IACR versions of this provision and those in all other programs are that only the CACR and IACR have subsection (b), and only the CACR and IACR versions include the term "services," as opposed to "services of any nature whatsoever." By all indications, "services of any nature whatsoever" merely clarifies what the scope of the term "services" means as a default proposition; it does not mean that the scope of "services" within the meaning of the CACR and IACR is narrower than it is in other sanctions programs.

2) See also Empresa Cubana Del Tabaco v. General Cigar Co., OFAC/Treasury Amicus Brief for interpretations this provision.