PRINT
LICENSE No. FNK-2017-345343-1
FOREIGN NARCOTICS KINGPIN SANCTIONS REGULATIONS
LICENSE
(Issued under the authority of one or more of the Foreign Narcotics Kingpin Designation Act, 21 U.S.C. §§ 1901-07, and 31 C.F.R. Parts 501 and 598)
To: Millennium Towers Residences Condominium Association, Inc.
(also known as The Four Seasons Residences)
c/o Bakalar & Associates, P.A.
12472 West Atlantic Boulevard
Coral Springs, FL 33071
Attn: Leonard Wilder, Esq.
1. Based upon your request dated June 28, 2017, on behalf of Millennium Towers Residences Condominium Association, Inc., and information otherwise available to the Office of Foreign Assets Control (the "Application"), the transactions described herein are hereby authorized.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and with all regulations, rulings,...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
1) Compare LICENSE No. FNK-2017-341112-2, dealing in part with the same blocked property.
2) Compare also LICENSE No. VENEZUELA-EO13850-2020-367941-1 (also allowing a condo association to foreclose on a blocked residence). That license authorizes "filing an in rem action for lien foreclosure, seeking as remedy the judicial sale of unit 7043 in order to satisfy those amounts due and payable to the Licensees." That license, and other items in the Research System, make clear that the mere filing of an in rem action for lien foreclosure requires a license. Here, the license is notable for the authorization covering “transmitting a demand letter, filing a lien against the Blocked Residences, and seeking foreclosure of said lien.”
Implicitly, OFAC regards merely “transmitting a demand letter” to a blocked entity to require a license. Seeing as that demand...