ENF 885319 - Pre-Penalty Notice

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 (649 words)

Consolidated Comment to Pre-Penalty Notice - Gracetown, Inc. and Penalty Notice -- Gracetown, Inc.

1) These Pre-Penalty and Penalty Notices (PDF pages 118 and 143, respectively) are the two most recent examples of such documents in the Research System, and set out OFAC’s views as to why OFAC believed the imposition of $8,022,832 was justified in light of the circumstances described in the notices. The native PDF file contains Gracetown Inc’s responses to the Penalty and Penalty Notices, which focus almost exclusively on OFAC application of the enforcement guidelines, rather than the threshold determination that violations were committed.

2) As noted in the comments to Enforcement Release: Gracetown, Inc., OFAC evidently did not consider Gracetown, Inc. to be a blocked person subsequent to the divestment by Deripaska shortly prior to his becoming a blocked person, notwithstanding that the owner after...

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ENF 885319 - Pre-Penalty Notice - Gracetown, Inc.

TURBOFAC Commentary (649 words)