31 CFR § 578.205 - Evasions; attempts; causing violations; conspiracies.

Date issued: Sep. 06 2022

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TURBOFAC Commentary (169 words)

Notes:

1) See General Note on the Apparent Scope of "Evasion/Avoidance" Provisions (System Ed. Note).

2) Unlike many others, this "Evasions; attempts; causing violations; conspiracies" provision is an updated version reflecting what OFAC considers to be the full reach of 50 USC § 1705 (IEEPA, Penalties). Note that, unlike the substantive prohibitions contained in these regulations (e.g. in dealing in blocked property), this section applies extraterritorially, to the point where even "conspiracies to cause" violations and "attempts to cause" violations can be pursued on a wholly extraterritorial basis. See Civil Enforcement Information - Ericsson, Inc. and Ericsson AB (2018), comments thereto, and General Note on Causing Violations From Abroad (System Ed. Note).

Older versions of the provision read as follows:

(a) Any transaction by a U.S. person or within the United States on or...