LICENSE No. FNK-2014-311428-1

Date issued: Dec. 02 2014

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TURBOFAC Commentary (236 words)

Notes:

1) The context of this forfeiture license is unusual in that the government filed the Verified Complaint for Forfeiture in Rem (in Aug. 2012) prior to the (Feb. 2013) blocking of the owner of the funds, and it was only after the warrant for arrest in rem had been issued that the funds became blocked. Based on the docket associated with this case, OFAC was evidently not of the view that the mere continuing with the forfeiture proceedings required a license (e.g. because it was a “judicial process…with respect to…” blocked property). See 598.202(e). Indeed, the license only after the “final judgment of forfeiture” (p. 8) had been issued.

2) § 1904(d) of the Kingpin Act (FNKDA) provides that “[n]othing in [the FNKDA] prohibits or otherwise limits the authorized law enforcement...