CTC Media: Selected Correspondence with the SEC (2014-2016)

Date issued: May. 18 2016

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TURBOFAC Commentary (3624 words)

Notes:

While the details concerning the sanctions related portion of the CTC Media (“CTC”) case are not laid out anywhere in a cohesive, narrative form, what can be pieced together from the totality of CTC’s 2014-2016 filings with the SEC constitutes what appears to be the best evidence on public record of how OFAC treats a wide variety of issues pertaining to a situation in which blocked persons are substantially involved in a publicly traded, U.S.-based company. The CTC Media case also involves treatment of blocked, U.S.-based holdings in a takeover context, confirming the broad applicability of the principles discernible from Letter in re: Nokia Corporation Proposed Acquisition of Alcatel Lucent (2015). The value of the case is derived partially from direct reporting by CTC on what OFAC had told the company, partially from the context of the filings, which make it clear that OFAC was intimately involved...