OFAC - FNKSR - General License 1C - Authorizing Certain Transactions and Activities to Liquidate and Wind Down Banco Continental, S.A. (Expired on June 14, 2017)

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Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

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TURBOFAC Commentary (312 words)

Notes:

1) Expired included in OFAC's "Archive of Revoked and Expired General Licenses."

2) The license is notable for the inclusion of "activities related to the preparation and submission of bids to acquire the assets of Banco Continental, S.A." as part of generally licensed activities. The suggestion is that, by implication, the "preparation of bids" constitutes "dealing" in property in which an has an interest. It is not evident just how much affirmative action must be taken before preparatory activities in contemplation of preparing a formal bid rise to the level of "transactions" in which the blocked person has an interest. Engaging outside services providers, such as accountants, would presumably cross that threshold.

That idea that OFAC would consider such activities to constitute a "dealing in" the blocked property,...

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FNKSR - General License 1C - Authorizing Certain Transactions and Activities to Liquidate and Wind Down Banco Continental, S.A. (Expired on June 14, 2017)

TURBOFAC Commentary (312 words)