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

Date issued: Aug. 01 2018

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TURBOFAC Commentary (401 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 CACR 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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