Case No. FNK-2017-345189-1

Date issued: Aug. 24 2017

Last substantive commentary amendment:
Apr. 03 2026

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TURBOFAC Commentary (1067 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) This guidance letter is similar identical to Case No. FNK-2015-324389-1, except that the entity at issue is different.

For general background on the case to which this guidance pertains, see the first part of the comments to Case No. FNK-2015-324389-1.

In Case No. FNK-2015-324389-1, the entity whose status as...