License No. FNK-2017-345343-1

Date issued: Feb. 23 2018

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TURBOFAC Commentary (305 words)

Notes:

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...