FAC No. FNK-474884 (Notable Third Party Notification of Blocking and Administrative Subpoena)

Date issued: Dec. 17 2010

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TURBOFAC Commentary (640 words)

Notes:

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...