LICENSE No. FNK-2018-358178-1

Date issued: Jun. 21 2021

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TURBOFAC Commentary (893 words)

Notes:

1) In 2017, OFAC designated Samark Lopez Bello as an SDN (https://home.treasury.gov/news/press-releases/as0005). On July 17, 2018, a condominium association sued the LLC that owned an apartment in which Lopez Bello had an interest (p. 18, PDF), seeking the judicial sale of the apartment without an OFAC license. The plaintiff condominium association did not seek an OFAC license prior to filing suit. The same apartment was the subject of an attachment proceeding under the TRIA.

2) The license authorizes "the initiation of a judicial sale of the Property," such that the licensee condominium association can recover "all outstanding obligations" owed to it, while depositing "all proceeds remaining from the sale of the Property into a blocked, interest bearing account located in the United States".

This aligns with what appears to be OFAC's standard...