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License No. NPW-1028
Weapons of Mass Destruction Proliferators Sanctions Regulations
LICENSE
(Granted under the authority of 50 U.S.C. § 1701 et seq, 50 U.S.C. § 1601 et seq., and 31 C.F.R. Part 501 and 544)
Citibank, N.A.
Compliance Division
201 S. Biscayne Blvd., Ste. 600
Miami, FL 33131
Attn: Mike Boriboon, Global Sanctions Compliance
1. Based upon your letter dated January 21, 2010, and additional correspondence dated August 30, 2010, on behalf of Citibank, N.A., to the Office of Foreign Assets Control (the "Application"), the transactions and activities delineated herein are hereby authorized.
2. This License is granted upon the statements and representations made in the Application or otherwise filed with or made to the Treasury Department as a supplement to the Application, or is based...
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1) As of 5-30-23, this is the only specific license on file authorizing the return of blocked letter of credit documents.
2) Note that, notwithstanding that there was a blocked person that had an interest in the letter of credit, the "License does not authorize the direct or indirect transfer of funds or services to or from any individual, entity, person or group whose property or interests in property are blocked..." This recognizes the distinction between dealing in property in which blocked persons have an interest (broader) and providing services to blocked persons (narrower). Refer generally to Notes Common to "Provision of services" and "Provision and receipt of services" Interpretive Provisions.