Enforcement Release: Fracht FWO Inc.

Date issued: Sep. 03 2025

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TURBOFAC Commentary (937 words)

Notes:

1) The VSR Violations

While certain aspects of the Fracht FWO case are notable, as described below, from a legal basis standpoint, the basic theory of liability does not break new legal ground. The U.S. person Fracht FWO received services from a blocked Venezuelan government entity and made payments to that entity, in both indirectly through a broker. Under these circumstances, there could be no question that the U.S. person was dealing in services in which the blocked person had an interest, and was making payments in which the blocked person had an interest. For another notable indirect dealing case, see Civil Enforcement Information - Eagle Shipping International (USA) LLC.

2) The GTSR and WMDPSR Violations and Significant for the Extinguishment...