Enforcement Release: An Unnamed Individual (21)

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 (188 words)

Notes:

1) This is a highly unusual enforcement action, both factually (first one that involves prohibited dealings in blocked real estate) as procedurally (by far the largest civil penalty assessed to an individual by OFAC). Contrast e.g. Case No. VENEZUELA-EO13850-2021-373786-1. There have been situations in the past in which blocked real estate located in the U.S. was the subject of an unlicensed foreclosure action; though in that case OFAC retroactively licensed the foreclosure proceeding given the apparent lack of knowledge of the blocking by all relevant parties, and required proceeds deposited into a blocked account. This case, by contrast, entails a set of facts that involves a remarkable degree of willfully illegal conduct on the part of a U.S. person where, as appears to be the case here, there was no concurrent criminal proceeding.

2) Rare but notable example of...

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Enforcement Release: An Unnamed Individual (21)

TURBOFAC Commentary (188 words)