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DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220
ADMINISTRATIVE SUBPOENA & NOTIFICATION OF BLOCKING OF THIRD PERSON
DEC 17 2010
FAC No. FNK-474884
Ayco Farms Inc.
ATTN: Avi Nir
730 South Powerline Road - Suite G
Deerfield Beach, FL 33442
Dear Mr. Nir:
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") administers a comprehensive economic sanctions program pursuant to the authority of the Foreign Narcotics Kingpin Designation Act ("Kingpin Act"), 21 U.S.C. 1901-1908, 8 U.S.C. 1182 (a)(2)(C). The Kingpin Act became effective on December 3, 1999, and is implemented by the Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. Part 598, and the Reporting, Procedures and Penalties Regulations, 31 C.F.R. Part 501 (collectively, the "Regulations").
You are hereby notified that on April 27, 2010 OFAC...
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1) 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 Individual (17), OFAC fined a U.S. person for being having provided, in the context of a ‘started a personal relationship, “jewelry, meals, clothing, hotel rooms, and other gifts” that were valued at “about $3,349.33.” In other words, there is no “personal relationship” exception to the FNKSR prohibitions.
Refer to discussion at comment 1 of ENF 43092 (Notable Third-Party Notification of Blocking - USP Daughter of Blocked Person). In both blocking notices, OFAC refers to "economic transactions" in...