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Case No. RUSSIA-EO14024-2024-1230210-1
Bertrand C. Sellier, Esq.
Rottenberg Lipman Rich, P.C.
230 Park Avenue, 18th Floor
New York, NY 10169
Dear Mr. Sellier:
This responds to your request to the Office of Foreign Assets Control (OFAC) dated May 15, 2024, and supplemental correspondence dated June 10, 2024, August 8, 2024, October 24, 2024, November 13, 2024, November 14, 2024, December 14, 2024, and March 27, 2025 (collectively, the “Application”), on behalf of Dr. Alexander Goldfarb, seeking a specific license to enforce a judgment in the amount of $25 million that was awarded to Dr. Goldfarb against Joint Stock Company Channel One Russia (Channel One Russia) on April 15, 2024 (the “Judgment”). The Judgment was awarded by Judge John P. Cronan of the United States District Court for the Southern District of New York in Goldfarb...
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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...