Enforcement Release: Key Holding, LLC

Date issued: Jul. 02 2025

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TURBOFAC Commentary (49 words)

Notes:

1) From a legal basis standpoint, this is a relatively straightforward violation arising out of the CACR's extension of jurisdiction to entities owned or controlled by U.S. persons (515.329). Compare the Cuba portion of Enforcement Release: C.H. Robinson International Inc. (similar factually, including the post-acquisition diligence failure).