OFAC SpaceX Correspondence (2014) (Related items included in original PDF)

Date issued: May. 08 2014

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TURBOFAC Commentary (509 words)


1) Context of correspondence is an injunction issued by a U.S. court (see attached PDF) against a U.S. company dealing with a Russian company purported to be controlled by an SDN, but where there was no allegation of ownership. As with other ordinary IEEPA-based programs, the relevant EO contained designation criteria allowing for the blocking of "persons determined by the Secretary of the Treasury, in consultation with the Secretary of State...to be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly... a person whose property and interests in property are blocked pursuant to [EO 13661]." As OFAC notes, however, this takes effect only upon an affirmative determination, rather than by operation of law. See General Note on the...