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THIRD PARTY NOTIFICATION OF BLOCKING
ENF 53208 [JAN 16 2019]
Amats Jet, Inc.
c/o E. Thomas Septembre
Frank Wolland
Keystone Law Firm, P.A.
12865 West Dixie Highway, Second Floor
North Miami, Florida 33161
Dear Mr. Septembre and Mr. Welland:
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) administers and enforces economic sanctions against targeted foreign countries, regimes, terrorists, international narcotics traffickers, and proliferators of weapons of mass destruction, among others. OFAC acts under Presidential national emergency authorities, as well as authority granted by specific legislation, to prohibit transactions and freeze assets under U.S. jurisdiction.
OFAC administers an economic sanctions program related to individuals and entities contributing to the situation in Venezuela (the "Sanctions Program") which is implemented by the Venezuela Sanctions Regulations, 31 C.F.R. part...
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*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...