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LICENSE No. MUL-2020-370795-1
IRANIAN TRANSACTIONS AND SANCTIONS REGULATIONS
GLOBAL TERRORISM SANCTIONS REGULATIONS
FOREIGN TERRORIST ORGANIZATIONS SANCTIONS REGULATIONS
WEAPONS OF MASS DESTRUCTION PROLIFERATORS SANCTIONS REGULATIONS
IRANIAN SECTOR AND HUMAN RIGHTS ABUSES SANCTIONS REGULATIONS
EXECUTIVE ORDER 13606
LICENSE
(Issued under the authority of one or more of 8 U.S.C. § 1189(a)(2)(C), 18 U.S.C. § 2339B(a)(2), 22 U.S.C. §§ 2349aa-9, 287c, 8501-51, 8701- 85, 50 U.S.C. §§ 1601-51, 1701-06, Executive Orders 12938, 12957, 12959, 13059, 13094, 13224, 13382, 13553, 13599, 13606, and 13846, and 31 C.F.R. Parts 501, 544, 560, 562, 594, and 597.)
To: U.S. Department of Justice
U.S. Attorney’s Office for the District of Columbia
555 Fourth Street NW
Washington, DC 20530
ATTN: Assistant U.S. Attorneys Brian P. Hudak and Michael P. Grady
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1) General Background
...(a) Timeline
...(b) Methodological Note
2) Analysis
...(a) Official Business
......(i) Background; the Differences Between the Two Licenses and Implied “Official Business” Determinations
......(ii) The Official Business GL As Covering Activities of Persons Acting “At the Direction” of the USG
...(b) The Meaning of “Transaction With” the IRGC for the Purposes of 561.202 of the IFSR; Implications for 560.215
...(c) Issues Related to the Operation of the Blocking Prohibition
......(i) Possession or Control” on the Date of the Issuance of the Seizure Warrant
......(ii) The Issuance of the Seizure Warrant and an “Area Under the Jurisdiction or Authority” of the United States
......(iii) “Termination…of an Interest in Blocked Property” – OFAC’s Jurisdiction Over the Subject Property...