31 CFR § 510.515 - Third-country diplomatic and consular funds transfers.

Date issued: Mar. 05 2018

TURBOFAC Commentary (214 words)

Notes:

1) Provision type common to all embargoes though with significant variations across programs. License only explicitly excludes "transfers involving accounts blocked pursuant to §510.201(d)." Those accounts, if outside of U.S. jurisdiction, are not technically not "blocked." With respect to all other frozen accounts, 542.502(e) applies "No license or other authorization contained in or issued pursuant to this part authorizes transfers of or payments from blocked property or debits to blocked accounts unless the license or other authorization explicitly authorizes the transfer of or payment from blocked property or the debit to a blocked account)."

2) Compare the broader CACR version (515.579). Presumably, given that this is a separate subsection of the CACR version in addition to the "operating expenses" part, the "personal expenditures of the employees, grantees, and contractors, or persons who share a common dwelling as a family member of such employees, grantees, and contractors, of third-country official missions" would fall outside the scope of "operating expenses," as it appears here.

3) The GL appears to permit the "facilitation" of transactions involving any type of person blocked pursuant to the NKSR, provided that the transaction is "necessary for the operating expenses or other official business of third-country diplomatic or consular missions in North Korea."