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Case No. SDGT-721c
Carpenter & Precup
206 North Washington Street, Suite 330
Alexandria, VA 22314-2528
Attn: Ronald G. Precup, Esq.
Dear Mr. Precup:
This responds to your letters dated September 14, 2009, and September 28, 2011 (the "Application"), from the Law Offices of Carpenter & Precup, on behalf of the People's Mojahedin Organization of Iran (the "Client"), to the Office of Foreign Assets Control ("OFAC"), requesting authorization to conduct transactions subject to the Global Terrorism Sanctions Regulations, 31 C.F.R. Part 594 (the "GTSR") and the Foreign Terrorist Organizations Sanctions Regulations, 31 C.F.R. Part 597 (the "FTOSR"). Specifically, you request authorization to receive payment for, and reimbursement of expenses incurred in connection with, legal services provided to the Client in connection with current proceedings seeking judicial review of the Client's designation as a Foreign Terrorist Organization under the...
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1) Query: for which portion of the GTSR GL for the provision of legal services (594.506) would "legal services provided to [a SDGT] in connection with current proceedings seeking judicial review of the Client's designation as a Foreign Terrorist Organization under the Antiterrorism and Effective Death Penalty Act" qualify? presumably subsection (a)(3) "[i]nitiation and conduct of domestic U.S. legal, arbitration, or administrative proceedings in defense of property interests subject to U.S. jurisdiction". The "in defense of property rights" has been removed from modern versions of the legal services GL, and there is cause to suspect, given that the scope of the legal services GL is generally consistent across programs, that the “defense of property rights” language is not construed strictly...