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Case No. LI2-2012-299385-1
Cornhill Capital Limited
c/o: Tannenbaum, Helpern,
Syracuse & Hirschtritt, LLP
900 Third Avenue
New York, NY 10022-4775
Attn: Michael G. Tannenbaum, Esq.
Dear Mr. Tannenbaum:
This responds to your letter dated December 20, 2012, and additional correspondence dated March 13, 2013, and June 5, 2013 (the “Application”), to the Office of Foreign Assets Control (“OFAC”), on behalf of Cornhill Capital Limited (“Cornhill”), an asset management company located in the United Kingdom. According to the Application, Cornhill manages the Cornhill Natural Resources Fund Limited (the “Fund”), in which the Libyan Investment Authority (“LIA”) made an investment on May 1, 2008. The Fund is held by prime broker Credit Suisse on Cornhill’s behalf. Cornhill seeks to transfer custody of the Fund to a new prime broker, UBS, which, in turn,...
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1) Background
As of the time of the issuance of the guidance letter (and still as of 3-3-24), the Government of Libya and all of its owned and controlled entities (including the Libyan Investment Authority (“LIA”)) were blocked pursuant to EO 13566. As OFAC reports in the letter, Libya - General License No. 8a authorizes all dealings with the GoL, except that certain property “blocked pursuant to Executive Order 13566…as of September 19, 2011” remain blocked, and Libya - General License No.11 separately unblocked all GoL property that remained blocked as a result Libya - General License No. 8a, with the exception of “funds, including cash, securities, bank accounts, and investment accounts, and precious metals of the [LIA]…blocked pursuant to Executive Order 13566…as of September 19, 2011.”
2) “Possession or...