31 CFR § 578.506 - Investment and reinvestment of certain funds.

Date issued: Sep. 06 2022

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TURBOFAC Commentary (187 words)

Notes Common to Most "Investment and reinvestment of certain funds authorized" General Licenses

This general license is common to over 15 sanctions programs that involve the blocking of assets, and is not included in sets of abbreviated sanctions regulations. As compared to the 200-level "Holding of funds in interest-bearing accounts; investment and reinvestment" provision that is cross-referenced, this provision appears to deal with securities and other asset classes not within the scope of the 200-level provision. It is not entirely clear how much discretion an investment manager has in determining how to reinvest funds, and OFAC does not appear to have provided public guidance on the question. If, for example, a holder of blocked corporate debt is repaid principal without an option to roll the debt over, may the proceeds be used toward reinvestment in any asset class? Furthermore, may funds be reinvested at the direction...