Case No. IA-[REDACTED] (Patton Boggs LLP, Jan 5, 2011)

Date issued: Jan. 05 2011

Last substantive commentary amendment:
May. 08 2023

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TURBOFAC Commentary (1008 words)

Notes:

1) Guidance articulates the "extinction of interest" principle, which, as of 5-5-23 is not otherwise found on OFAC's website (at least as it relates specifically to funds). OFAC considers that, so long as funds at an SDN bank first come to rest at a non-SDN bank as a result of a transaction otherwise outside the scope of OFAC's jurisdiction, those funds can then be sent to the U.S. via a separate transfer without OFAC considering the second leg of the transaction being either i) an "indirect" dealing in property in which the SDN bank has an interest, ii) a transaction "related to" the services of that SDN bank, or iii) dealing in property in which the SDN bank has an ongoing "interest."

Note that all three of those concepts are, in other situations, interpreted in an extremely broad manner.