Civil Enforcement Information - Cobham Holdings, Inc.

Date issued: Nov. 27 2018

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TURBOFAC Commentary (967 words)

Notes:

1) Basis for liability: OFAC cites 598.201, which incorporates by reference the prohibitions EO 13661 of which Sec. 4(a) specifies that dealings in blocked property include "the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any person whose property and interests in property are blocked pursuant to [the] order." This would be an uncommon case of an "indirect dealing" with a blocked party, which OFAC clarified is prohibited across all sanctions programs in its 2014 "Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property Are Blocked."

2) Given the amount of factual detail provided relative to amount of the penalty, this enforcement action appears squarely aimed at serving as notice to the regulated community as to OFAC's compliance expectations. There are several novel aspects...