LICENSE No. MUL-2020-370795-1, LICENSE No. MUL-2020-370795-2 [Application Included], LICENSE No. MUL-2020-370795-3

Date issued: Apr. 13 2022

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TURBOFAC Commentary (5205 words)

Notes:

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...