Case No. FNK-2015-324389-1 [Application included in PDF]

Date issued: Apr. 01 2016

Last substantive commentary amendment:
Apr. 03 2026

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (2745 words)

Notes:

[Update: on May 17, 2021, the FNKSR were modernized to bring its text in line with that of the typical set of blocking regulations. The change was non-substantive. See comments to 598.202. The below has not been amended to reflect the May 17, 2021 amendments to the FNKSR]

[2026-04-04 update - read in light of OFAC's 2026 Sham Transactions Guidance. The below has not yet been updated to reflect the issuance of the Sham Transactions Guidance].

1) Notes on the background to the United States v. Jaime Rolando Rosenthal Oliva et al Unpublished Interpretive Guidance Letters.

a) Guidance letters issued in connection with United States v. Jaime Rolando Rosenthal Oliva et al., S2 13 Cr. 413 (JGK) (S.D.N.Y.), a criminal case against members of a Honduran...