LICENSE No. LB-2013-304927-1

Date issued: Oct. 21 2013

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TURBOFAC Commentary (334 words)

Notes:

1) Unusual license illustrative of a licensing policy for the unblocking of funds that is not otherwise discernible from OFAC's regulations and other guidance. Note in addition that the license was issued pursuant to a court order (p. 3 PDF) "directing" OFAC to issue a license unblocking the funds. In theory, OFAC could have refused, setting up a “separation of powers” dispute over OFAC’s authority to deny the unblocking of funds for activities incident to courtroom proceedings. In any event, the license is notable as a rare case of a court directing OFAC to unblock funds, and OFAC acquiescing to the directive. The court order was, arguably, "null and void" as issued, per 593.202(e) ("Except to the extent otherwise provided by law, unless licensed pursuant to this part, any attachment, judgment, decree, lien, execution, garnishment, or other judicial process is null and void with respect to...