LICENSE No. MUL-2013-305239-3

Date issued: Sep. 19 2016

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TURBOFAC Commentary (219 words)

Notes:

1) See comments to Case No. SDGT-2019-363638-1 [Documents related to related legal challenge in original PDF], for further discussion of the context in which this specific license was released. Note that the license only authorized the transfer of custody of the property at issue. Escheatment pursuant to the license did not alter property rights.

2) Compare License No. [Redacted] 10-1-02. These are the only two specific licenses of which we are aware that, on their faces, authorize transactions prohibited by sanctions programs that may not yet exist (reference to property required to "be blocked pursuant to any sanctions programs administered by the Office of Foreign Assets Control").

3) Compare 515.554 of the