2026 Email from OFAC in re: U.S. Person Funding of Litigation Benefitting an SDN [Query in PDF]

Date issued: Apr. 15 2026

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TURBOFAC Commentary (290 words)

Notes:

1) The attorney that submitted the query represented two non-sanctioned family members of an SDN in a lawsuit in U.S. court. One of the family members was a U.S. person, the other was a non-U.S. person. The lawsuit was brought “on his own behalf as well as on behalf of his [SDN] wife, who is barred from bringing claims in her own name by a United Nations policy that precludes her from contesting the sanctions imposed on her.” (See para. 12, https://storage.courtlistener.com/recap/gov.uscourts.dcd.289767/gov.uscourts.dcd.289767.1.0.pdf). The sanctions regulations at issue contained standard GLs for legal services (528.506) and related payments (528.507). OFAC confirms that the legal services GL covers the representation of non-sanction persons bringing lawsuits on their own behalf and on behalf of blocked clients. There is, in this case, no apparent need for...