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LICENSE No. SY-2012-299140-1
SYRIAN SANCTIONS REGULATIONS
LICENSE
To: The Estate of Ghassan Koujan
c/o [ ]
1455 Pennsylvania Avenue, NW
Suite 400
Washington, District of Columbia
20004
ATTN: [ ]
1. Based upon your letters dated December 12, 2012, February 15, 2013, and May 28, 2013, to the Office of Foreign Assets Control (the “Application”), the transactions and activities delineated herein are 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 on information otherwise available to the Treasury Department, and is subject to the condition, among others, that the Licensees will comply in all respects with all regulations, rulings, orders, and...
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1) While it should not be difficult to understand why OFAC’s licensing policy would support the transactions that are the subject of the license, this is the only specific license in the Research System (as of 2024) authorizing payments in connection with settlement agreements concluded in the U.S. Here, the payees are family members, ordinarily resident in Syria, of an individual that died in a plane crash (see https://nypost.com/1999/11/03/fate-cheated-hard-working-chef-he-planned-to-bring-family-to-america/). The license covers transfers to “accounts…located at financial institutions in Lebanon and Syria,” making it clear that payments to accounts located in Lebanon require a license to the extent that the beneficiary is ordinarily resident in Syria. The license is also notable for its three-year validity (only in rare cases are licenses issued for a period beyond two years).