Case No. FNK-2017-344870-1; LICENSE No. FNK-2017-344870-1

Date issued: Dec. 05 2017

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (170 words)

Notes:

1) License illustrative of OFAC's generally favorable, unwritten licensing policy concerning U.S. persons’ receipt of payments (out of “fresh funds”) that are owed by blocked persons in connection with pre-designation activities. Read in conjunction with the cover letter, which denies the request to release funds held by the applicant "as security on [the] commercial lease agreement entered into between" the applicant and the blocked person. Those funds were within the "possession and control" of a blocked person at the time the application was made, and are therefore subject to a different licensing policy than "fresh funds".

2) Note that the applicant landlord requests authorization to "execute on a writ of possession," which in practical terms means the ability to physically evict a tenant. This aspect of the license request to have been granted.

3) See General...