Case No. COTED-6-1

Date issued: Apr. 22 2014

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TURBOFAC Commentary (2306 words)

Notes

1) BACKGROUND

In October and November of 2010 (first and second round, respectively), Laurent Gbagbo, the then-President of Cȏte d’Ivoire (CdI), ran an election against Alassane Ouattura. The results of the election were contested, with the Ivorian "Constitutional Council" finding Gbagbo to be winner due to alleged irregularities in parts of the country, with the "Independent Election Commission" declaring Ouattura to be the winner. As a result, both Gbagbo and Ouattura declared themselves to be the winners and took the presidential oath of office (https://en.wikipedia.org/wiki/Laurent_Gbagbo).

At that point, the CdI-related E.O. 13396 was in effect, but neither Gbagbo nor the Government of CdI ("GoCdI") were sanctioned or otherwise blocked by OFAC.

In late 2010, after the election, the GoCdI, through the CdI embassy to the U.S., contracted the law firm of U.S. lawyer and lobbyist Lanny Davis (LID&A) to...