Askan Holdings Ltd. v. Office of Foreign Assets Control et al (D.D.C. 2020) - Second OFAC Director's Declaration

Date issued: Jan. 15 2021

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TURBOFAC Commentary (357 words)

Notes:

1) See comments to Case No. SDGT-2019-363638-1 [Documents related to related legal challenge in original PDF] for discussion of the facts underlying the litigation in which this Declaration was made. To the degree that the Declaration discloses facts that help illuminate the licensing determinations with respect to the funds at issue in Case No. SDGT-2019-363638-1, those facts are discussed in the comments to Case No. SDGT-2019-363638-1.

2) The Declaration is notable for a few licensing policy-related statements that are not made elsewhere (and do not relate to the specific license for escheatment of blocked property by NY State, details of which are discussed at LICENSE No. MUL-2013-305239-3).

i) First, there is the following statement:

“international organizations, such as the United Nations (“UN”) will...