Case No. CU-77689

Date issued: Aug. 25 2009

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TURBOFAC Commentary (331 words)

Notes:

1) OFAC Confirms that, notwithstanding the text of 515.203(e) of the CACR, no license is required to "execute on a judgment against blocked property in accordance with the requirements of section 201 (a) of the Terrorism Risk Insurance Act of 2002." Accord Stansell et al v. FARC et al. 8:09-cv-02308-CEH-AAS (Dkt. 1197) (M.D.FL. 2019) – USG Statement of Interest (2019). See also Harrison v. Republic of Sudan, 802 F.3d 399 (2d Cir. 2015) (no OFAC license or case-specific statement from the DOJ is required).

This appears to constitute a reversal from OFAC's earlier-held position. See Letter From R. Richard Newcomb to Citigroup re: TRIA Attachment (2004) (OFAC says that the determination of whether "assets...are to...