OFAC Enforcement - WATG Holdings, Inc., and Its Subsidiary, Wimberly Allison Tong and Goo (UK) Limited

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (383 words)

Notes:

1) There is no evidence of U.S. company involvement here, jurisdiction based solely on UK subsidiary being subject to the Jurisdiction of the United States for the purposes of the (515.329).

2) Multiple actions described as if they were separate offenses, but the base penalty amount suggests that OFAC considered all of the actions taken to constitute a single offense. OFAC has counted actions similarly disparate though relating to a single deal as multiple violations in cases in which there was evasion or deception involved.

3) This appears to be work undertaken pursuant to a subcontract. Here there is probably no Cuban "legally cognizably interest," or "property interest," in, for example, the write-off of the contract’s original value (to which no Cuban is likely to have been party). Yet OFAC...

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Civil Enforcement Information - WATG Holdings, Inc., and Its Subsidiary, Wimberly Allison Tong and Goo (UK) Limited

TURBOFAC Commentary (383 words)