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Case No. MUL-2018-357305-1
[****]
Cambridge Mercantile Corp. (U.S.A.)
3 Bala Plaza East, Suite 117
Bala Cynwyd, PA 19004
Dear [****]
This responds to your request dated October 1,2018, and additional correspondence dated January 7, 2019 (collectively, the “Application”), to the Office of Foreign Assets Control (OFAC), seeking guidance on whether authorization is required for Cambridge Mercantile Corp. (U.S.A.) (“Cambridge”) to facilitate payment for legal services performed on behalf of [****] a Specially Designated National (SDN) under both Executive Order (E.O.) 13661 and the Ukraine Related Sanctions Regulations (URSR), 31 C.F.R. Part 589, and E.O. 13694 and the Cyber-Related Sanctions Regulations (CRSR), 31 C.F.R. Part 578.
According to the Application, Cambridge received an invoice from the U.S. law firm [****] in connection with the [****] of [****] in the United States District Court [****]. The Application...
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1) Cambridge Mercantile Corp. (U.S.A.) operates “Corpay,” which is an accounts payable system used by companies to process cross-border payments. Here, Cambridge Mercantile Corp. says that it “received an invoice from the U.S. law firm” (presumably for processing) where the payment was in connection with “legal services performed on behalf of” and SDN (i.e. something in connection with proceeding taking place in a U.S. District Court). OFAC recounts that “the invoice instructs payment be made to a Russian law firm” that has a bank account at a (presumably Russian) bank subject to the new debt prohibitions of SSI Directive 1. The SDN was blocked pursuant to the URSR and Cyber regulations, both containing standard legal services GLs at 589.506(a) and 578.506(a).
OFAC says “[a]ssuming that the...