LICENSE No. CU-2018-354788-1 [Application Included]

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

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).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (411 words)

Notes:

1) This specific license and associated application illustrate two important aspects of OFAC's licensing practices that are not otherwise discernible from the regulations.

First, the applicant asks for what is, in a sense, a sort of "wind down" license. OFAC allows a non-U.S. person that would have become subject to the 515.329(d) as a result of being acquired by a U.S. person to complete certain activities post-acquisition that would have otherwise been prohibited. Note that the application was made prior to the closing of the acquisition transaction, but the license was granted soon after the acquisition transaction closed. It is not clear whether OFAC would have been willing to grant the license contingent on the deal closing and Silver Cloud becoming a U.S. person.

Second, § 7209 TSRA of provides as follows:

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LICENSE No. CU-2018-354788-1 [Application Included]

TURBOFAC Commentary (411 words)