General Note on the Boilerplate Provision Titled “Effect of Transfers Violating the Provisions of This Part”; “Null and Void” Transfers (System Ed. Note)

Last substantive commentary amendment:
Nov. 17 2024

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TURBOFAC Commentary (2996 words)

General Note on the Boilerplate Provision Titled “Effect of Transfers Violating the Provisions of This Part”; “Null and Void” Transfers (System Ed. Note)

1) BACKGROUND

All sets of regulations that implement blocking prohibitions have a provision (usually but not always 5XX.202) titled “Effect of transfers violating the provisions of this part”. A recent (2021) version of the provision, which is generally boilerplate across programs on substance, is reproduced in part below:

§ 525.202 Effect of transfers violating the provisions of this part.
(a) Any transfer after the effective date that is in violation of any provision of this part or of any regulation, order, directive, ruling, instruction, or license issued pursuant to this part, and that involves any property or interest in property blocked pursuant to § 525.201, is null and void and shall not be the basis for the assertion or...