License No. BALKANS-EO14033-2025-1413354-1

Date issued: Sep. 09 2025

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (249 words)

Notes:

1) This license is unique among all those included in the Research System. There are other specific licenses that effectively unblock otherwise blocked persons in connection with going-forward transactions (see e.g. LICENSE No. VENEZUELA-EO13850-2019-360364-7), but this one is different because (i) it pertains to an actual SDN, as opposed to certain entities blocked pursuant to the 50 percent Rule, and most notably (ii) it was issued to the Department of State, rather than the actual SDN or any other ordinary U.S. person seeking to engage in transactions with the SDN. The license served to allow U.S. persons to engage in otherwise prohibited transactions involving the SDN even if they were not aware of and did not have possession of the license (compare e.g. Case No. CU-79012).

2) The blocked person at issue was...