All property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any United States person (including any foreign branch) of a person, organization, or entity designated by the Secretary of the Treasury’s Office of Foreign Assets Control (OFAC). Once such property or interests in property are in the possession of a U.S. person or someone subject to U.S. jurisdiction it may not be may not be transferred, paid, exported, withdrawn, or otherwise dealt in. Hence, the property is considered blocked or frozen.
Property and Interests in Property
Although the Executive Order 13685 (pdf) does not define “property” or “interests in property,” other OFAC administered sanctions programs shed light on what the terms mean. This definition is from the Burmese Sanctions Regulations (31 C.F.R. Part 537):
Definition of Transfer
In essence, everything related to finance, commerce, business, real estate, or anything of value, either in the past, present or future, is subject to being blocked or frozen. Equally daunting is the definition of transfer. Virtually any movement or alteration of a blocked or frozen asset is prohibited. This definition of prohibited “transfers” is also from the Burmese Sanctions Regulations:
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