Case No. RUSSIA-EO14024-2024-1230210-1

Date issued: May. 07 2025

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TURBOFAC Commentary (412 words)

Notes:

1) The litigation to which this guidance letter relates involves a U.S. person being awarded a $25 million judgment against an SDN for libel claims brought in federal court under New York law. See complaint at p. 3 (PDF) et seq., and see default judgment at p. 46. The plaintiff, a “judgment creditor” once the judgment was issued, located certain payables owed to the SDN judgment creditor that were owed by U.S. persons, and were therefore “blocked property” within the meaning of OFAC’s regulations (a “debt” is property and a blocked person has an “interest” therein when the debt is owed to the blocked property). OFAC described this as “assets as being held in the United States as funds owed to” the SDN.

2) The guidance letter is particularly notable for the blanket statement that “creditors may file for writs of...