FAC No. SDT-197007 (Sample Requirement to Furnish Information)

Date issued: Nov. 28 2001

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TURBOFAC Commentary (27 words)

Notes:

1) For commentary on this document and the related case in the context of OFAC’s authority to block persons and assets pending investigation, see of General Note on the Blocking of Persons and Property Pending Investigation.

2) The RFI is also notable as an example of OFAC making an affirmative “interest” determination with regard to a specific asset owned by a person alleged to be affiliated with an SDGT. In theory, all property in which a blocked person has an “interest” is blocked by operation of law, irrespective of whether OFAC makes an affirmative determination of “interest.” Here OFAC blocks a specific account on the basis of an affirmative “interest” determination, but not other assets or property of the U.S. person. As is the case...