OFAC Enforcement - CWT B.V.

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 (3234 words)

Consolidated Comment on CWT B.V. (2014) and BCC Corporate SA (2017)

1) GENERAL BACKGROUND

The enforcement actions against CWT B.V. (2014) and BCC Corporate SA (2017) are, in one important sense, closely related "companion cases" illustrating the breadth and limitations of 515.329(d) of the . 515.329(d) specifies that any entity, wherever located, is subject to the prohibitions of the CACR if it is "owned or controlled by" one or more persons described as a "corporation, partnership, association, or other organization organized under the laws of the United States or of any State, territory, possession, or district of the United States."

The terms "owned" or "controlled" are not defined in the CACR. Note that nothing in the CACR states that a foreign entity is necessarily subject to the CACR if it is "owned or controlled by"...

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Civil Enforcement Information - CWT B.V.

TURBOFAC Commentary (3234 words)