ICC-related General License 2 - Authorizing the Provision of Certain Legal Services (June 05, 2025)

Date issued: Jun. 05 2025

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TURBOFAC Commentary (197 words)

Notes:

1) All sanctions regulations contain a GL allowing for the provision of certain legal services. The GL is, with some exceptions, boilerplate across sanctions programs, albeit with substantial variability on the question of whether or not payments for such services require a specific license. Read in conjunction with the GL dealing with payments for legal services (ICC-related General License 3).

Refer to Notes Common to most Versions of the "Provision of Legal Services" General License (System Ed. Note).

2) As is the case with most recent sanctions programs, this provision contains a reference to a general license for the receipt of legal fees.

3) Unlike older versions of this provision, 552.207(b) refers to "[t]he provision of any other legal services to or on behalf of persons whose property and interests in property are blocked pursuant to."...