Civil Enforcement Information - World Fuel Services Corporation

Date issued: Sep. 09 2013

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TURBOFAC Commentary (467 words)

Notes:

1) Bases for liability

a) Iran: If the fuel arrived from outside of Iran, facilitation of the export of the fuel itself to Iran (560.208) or, if already in Iran, a transaction related to Iranian-origin goods and services (560.206), since the port is considered "Iran" for the purposes of that provision.

b) Cuba: Facilitation of the export of the planes to Cuba, or in CACR terms, dealing in "services" in which a Cuban had an interest (515.201(b)).

c) Sudan: There is nothing to suggest that the plane was not actually in Sudan at the time in which the services were rendered and goods supplied. This would clearly constitute the support of Sudan-related trading activity if the plane was in Sudan. A different question is whether supplying fuel...