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31 CFR § 594.201 - Prohibited transactions involving blocked property.

Date issued: Jul. 01 2022

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§ 594.201 Prohibited transactions involving blocked property.

(a) Except as authorized by statutes, regulations, orders, directives, rulings, instructions, licenses or otherwise, and notwithstanding any contracts entered into or any license or permit granted prior to the effective date, property and interests in property of the following persons that are in the United States, that hereafter come within the United States, or that hereafter come within the possession or control of U.S. persons, including their overseas branches, are blocked and may not be transferred, paid, exported, withdrawn or otherwise dealt in:
(1) Persons listed in the Annex to Executive Order (E.O.) 13224 of September 23, 2001, as amended;
(2) Foreign persons determined by the Secretary of State, in consultation with the Secretary of the Treasury, the Attorney General, and the Secretary of Homeland Security:
(i) To have committed or have attempted to commit, to pose...

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TURBOFAC Commentary (3712 words)

Notes:

*Update - provision amended on 7-1-22 to remove "otherwise associated with" as a basis for designation (i.e. being "otherwise associated with" SDGTs).
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1) Except as discussed below, this is a standard blocking prohibition, as it appears in a non-abbreviated set of sanctions regulations that incorporate into the regulations the primary and derivative designation criteria used to determine the range of persons with respect to which blocking prohibitions apply. Read in conjunction with 594.204 (Prohibited transaction or dealing in property; contributions of funds, goods, or services). In the vast majority of sanctions programs, i.e. all except for the TSR and GTSR, the substance of that prohibition is not cast as a separate prohibition, but is instead included within the scope of the basic 5XX.201 blocking prohibition. See e.g. 588.201(b). For practical purposes, 594.204 serves as an "interpretive" provision, interpreting...