31 CFR § 542.305 - Government of Syria.

Date issued: May. 02 2014

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TURBOFAC Commentary (1467 words)


1) Note on the Relationship Between the "50% rule" and the Regulatory Definitions of "Government of [X]"

Any “person” (i.e. individual or entity) that meets the applicable definitions of "Government of Venezuela," "Government of Syria," "Government of North Korea" or "Government of Iran" is blocked. In all four cases, the applicable definitions [1] provide that an ENTITY meets the definition of "Government of [X]" if it is one that is "owned or controlled, directly or indirectly" by the blocked government.

In three of the four cases, OFAC's regulations specify that an ENTITY meets the definition of "Government of [Syria/Iran/North Korea]" if it is one in which the government owns "owns a 50 percent or greater interest or a controlling interest." This is not the case for Venezuela.

In all four cases, a person is blocked if the person is one in which...