Case No. SDGT-1329 (Additional Information in Original PDF)

Date issued: Mar. 10 2010

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TURBOFAC Commentary (1870 words)

Notes:

1) This guidance letter should be read in conjunction with Case No. SDGT-1051. In that letter, issued 11 months prior to this one, OFAC says that a U.S. person may send funds to the parent organization of an entity blocked as an SDGT. The blocked entities were blocked pursuant to the GTSR (EO 13224) for providing financial support to al-Qaeda, which was at the time (and is now) itself an SDGT, as well as an FTO such that payments involving the entity and its "agents" are subject to the FTOSR.

Sec. 1(d)(i) of EO 13224 provides for the blocking of all persons determined "to...