Case No. LI2-2012-299385-1

Date issued: Jul. 11 2013

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TURBOFAC Commentary (633 words)

Notes:

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...