LICENSE No. SY-2012-299140-1

Date issued: Jun. 17 2013

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TURBOFAC Commentary (147 words)

Notes:

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).