ENF 53208 (Notable Third Party Notification of Blocking - Aircraft)

Date issued: Jan. 16 2019

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TURBOFAC Commentary (2437 words)

Notes:

*UPDATE: On 24 September 2019, the aircraft at issue was removed from the SDN list. The below was drafted prior to the delisting. The delisting was evidently done in recognition of the legitimacy of the arm's length sale of the aircraft indirectly from a soon-to-be-blocked person to an ordinary U.S. person. The blocked person did not retain an "interest" in the plane subsequent to the sale that carried through to the effective date of his blocking. OFAC stated that "OFAC has determined that aircraft N133JA is no longer associated with [the relevant blocked individual]." See https://home.treasury.gov/news/press-releases/sm784.

*UPDATE: In November 2019, the VSR were amended such that all transactions prohibited by any Venezuela-related EO, including EO 13850, were prohibited by 591.201 of the VSR. The amendment explicitly links the VSR to...