When OFAC refers to an “entity”, what do they mean?
Well, it’s not the same thing as “entity” from the dictionary… Dictionary.com includes the following definition:
being or existence, especially when considered as distinct, independent or self-contained
Executive Order 13224, for example, makes it plain, from OFAC’s point of view:
the term “entity” means a partnership, association, corporation, or other organization, group, or subgroup
So, anything that appears on the SDN List that isn’t a person or cargo vessel is an entity.
Depending on who you are speaking to, you might run into one or the other usage.
Categories: General Information