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LICENSE No. GLOMAG-2021-371648-1
GLOBAL MAGNITSKY SANCTIONS REGULATIONS
LICENSE
(Issued under the authority of one or more of 50 U.S.C. §§ 1601-51, 1701-06, Pub. L. 114-328, Executive Order 13818, and 31 C.F.R. Parts 501 and 583.)
To: Arnold & Porter Kaye Scholer LLP
601 Massachusetts Avenue, N.W.
Washington, D.C. 20001
Attn: Baruch Weiss, Esq.
1. Based upon, inter alia, the information dated December 3, 2020, submitted on behalf of Mr. Dan Gertler, to the Office of Foreign Assets Control, 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, orders, and instructions issued under any of the authorities cited above.
3. This License expires on January 31, 2022...
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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...