Case No. CU-2013-300818-4

Date issued: Mar. 15 2017

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TURBOFAC Commentary (497 words)

Consolidated Comment to Case No. CU-2013-300818-4 and Case No. CU-2013-300818-5

1) Both “comment” letters relate to applications for specific license renewals submitted by an attorney that represented, in Florida probate court, Cuban heirs to U.S.-based estates as a Guardian Ad Litem. In the comment letters, OFAC says that the combination of 515.523, 515.524, and 515.570(f)(1) authorize the transactions referred to in the application, i.e. representing Cuban heirs and remitting estate proceeds.

515.523 (last amended Sept. 21, 2015) authorizes “[a]ll transactions incident to the administration and distribution of the assets of a blocked estate of a decedent.” (Note that the case in which these documents were filed relates to acting as Guardian Ad Litem for Cuban heirs of the estate of an unblocked U.S. person - see PDF).

515.524 (last amended Sept. 21, 2015) authorizes U.S. bank trustees to make payments to...