Case No. VENEZUELA-EO13850-2022-950943-1

Date issued: Jul. 19 2022

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TURBOFAC Commentary (710 words)

Notes:

1) For relevant factual background concerning related case, see comments to LICENSE No. VENEZUELA-EO13850-2019-359725-3.

2) OFAC JURISDICTION OVER IN REM LITIGATION; CIVIL FORFEITURE ACTIONS FOCUSING ON BLOCKED PROPERTY

This guidance letter is notable for the proposition that OFAC asserts jurisdiction over the mere filing, by the U.S. government (i.e. the DOJ), of a civil forfeiture action that focuses on blocked property. See generally section 3.3 of General Note Concerning Unlicensed Litigation Involving Sanctioned Persons or Property; the Question of Whether Judicial Action Constitutes the Unlicensed "Transfer" of Blocked Property (System Ed. Note) (no license is required to file a suit against a blocked person, but in rem litigation were blocked persons are defendants evidently require a license).

3) SCOPE OF THE “OFFICIAL BUSINESS”