ENF 43092 (Notable Third Party Notification of Blocking - USP Daughter of Blocked Person)

Date issued: Apr. 15 2015

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (630 words)

Notes:

1) This “Notification of Blocking of a Third Person” was sent to the daughter of Abigael Gonzalez Valencia, who was the leader of the Jalisco New Generation Cartel. Both Gonzalez Valencia and the cartel were designated pursuant to the FNKDA on April 8, 2015, as was the recipient’s uncle. The recipient of the notice, Oseguera Gonzalez, is a dual Mexican-U.S. citizen that, at the time the notice was sent, lived full time in Mexico with intermittent travel to the U.S. [1]

2) A U.S. PERSON'S "NON-ECONOMIC" ACTIVITIES INVOLVING BLOCKED PERSONS


A significant gray area of sanctions law is the extent to which sanctions laws cover “personal relationships” between U.S. persons and sanctioned individuals. Note that the FNKSR has no general license for “personal communications.” In An Unnamed...