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OFFICE OF FOREIGN ASSETS CONTROL
Foreign Narcotics Kingpin Sanctions Regulations
31 C.F.R. Part 598
GENERAL LICENSE NO. 4G
Authorizing Certain Transactions Involving the Panamanian Mall and Associated Complex, Soho Panama, S.A. (a.k.a. Soho Mall Panama)
(a) General License No. 4F, dated March 9, 2017, is replaced and superseded in its entirety by this General License No. 4G.
(b) Except as provided in paragraph (c), the following transactions and activities otherwise prohibited by the Foreign Narcotics Kingpin Designation Act, 21 U.S.C. 1901- 1908, and the Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598, are authorized through 12:01 a.m. eastern daylight time, June 15, 2017:
(1) All transactions or activities involving non-designated individuals or entities located in the designated Panamanian mall and associated complex, Soho Panama, S.A. (a.k.a. Soho Mall Panama) (hereinafter Soho...
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1) Expired GL included in OFAC's "Archive of Revoked and Expired General Licenses."
2) Refer to OFAC FAQ # 472 (Removed) - General Licenses Issued Authorizing Certain Activities Pertaining to Panama.
3) While expired, this GL has continued cross-programmatic interpretive value concerning the notion of a blocked person having an "interest" in property.
Here, the license pertains to a blocked SDN mall operator/complex, as well as "non-designated individuals or entities located in the designated [] mall and associated complex." These include individual stores within the mall complex, many of which were large international brands. The GL gives no reason to believe or suspect that this entire class of non-designated entities consists of entities blocked pursuant to the 50% rule for being owned by the...