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To: "[xxx]@arktouros.co" <[xxx]@arktouros.co>
Wed, Apr 15, 2026 at 6:50 PM
Thank you for your follow-up query: OFAC-2026-010550.
The general license at 31 CFR § 528.506 authorizes certain legal services to or on behalf of persons whose property and interests in property are blocked pursuant to § 528.201, provided that any receipt of payment of professional fees and reimbursement of incurred expenses must be authorized pursuant to 31 CFR § 528.507. 31 CFR§ 528.507 does not authorize any payments from: (i) a source within the United States; (ii) any source, wherever located, within the possession or control of a U.S. person; or (iii) any individual or entity, other than the person on whose behalf the legal services authorized pursuant to § 528.506(a) are to be provided, whose property and interests in property...
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...