FAC No. SDGT-197443 - Holy Land Found. Blocking Notice

Date issued: Dec. 04 2001

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TURBOFAC Commentary (325 words)

Notes:

1) Blocking notice issued in connection with a U.S. government raid of the headquarters of an SDGT-designated, U.S.-person entity [1].

The following passage is notable:

All transactions involving property in which Holy Land has any interest, including any property of third parties in the possession or control of Holy Land, are prohibited without specific authorization from OFAC.

This is an articulation of the concept of a "possessory interest," which is a type of non-ownership "interest" within the scope of the basic blocking regulation.

The blocking of a person requires U.S. persons to physically block all property, in which a blocked person has an interest, that is within the "possession or control" of a U.S. person.

Here, OFAC construes the basic blocking prohibition such...