LICENSE No. GLOMAG-2021-371648-1

Date issued: Jan. 15 2021

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TURBOFAC Commentary (569 words)

Notes:

1) On December 21, 2017, Dan Gertler and over a dozen entities associated him were sanctioned pursuant to Executive Order 13818 of December 20, 2017, which is based, in part, on the “Global Magnitsky Human Rights Accountability Act.” On June 15, 2018, OFAC designated another “14 entities pursuant to Executive Order (E.O.) 13818, which targets serious human rights abuse and corruption, for being affiliated with designated Israeli businessman and billionaire Dan Gertler.”

[1] https://home.treasury.gov/news/press-releases/sm0417
[2] https://home.treasury.gov/news/press-releases/sm0417

2) This license, issued five days prior to the end of then-President Trump’s term, is extremely rare insofar as it is effectively a full unblocking license—i.e. one that authorizes transactions on a prospective basis as well as the unblocking of property that is actually within the possession or control of a U.S. person—that is issued to a set of persons that remained...