LICENSE No. FNK-2020-369869-1

Date issued: Jan. 07 2021

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TURBOFAC Commentary (123 words)

Notes:

1) Compare LICENSE No. VENEZUELA-EO13850-2019-359725-3 and query: what determines whether OFAC allows for payments for assessments and other maintenance-related expenses to come from income generated by blocked property (as opposed to "fresh funds" of the blocked owner)?

Note that when units in a condo building are blocked, it is not the case that the blocked owner has an "interest" in the entirety of the building (or other common areas to which the blocked person has access). Here, the "Units" are the " properties in which Gaston Tomaghelli has an interest," not other aspects of the building. Compare ENF 47102.

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