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LICENSE No. FNK-2018-358178-1
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: Lagorce Palace Condominium Association, Inc.
c/o Alayon & Associates, P.A.
135 San Lorenzo Ave – Suite 820 Coral Gables, FL 33145
Attn: Richard Alayon
1. Based on the request dated November 20, 2018 and letter dated March 23, 2021, on behalf of Lagorce Palace Condominium Association, Inc 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 comply with its terms and with all regulations, rulings, orders, and instructions issued under one...
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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...