LICENSE No. UKRAINE-EO13685-2024-1241527-1

Date issued: Aug. 23 2024

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TURBOFAC Commentary (912 words)

Notes

1) See PDF for details concerning the civil forfeiture action to which this license is related. The license is notable for a few reasons.

2) [Licensing Policy] First, it illustrates OFAC’s favorable licensing policy for the vesting (by the USG) of blocked property that is subject to civil forfeiture actions based on allegations that the blocked property is tied to an underlying criminal offense (typically the violation of sanctions regulations is one of them).

3) [Ordinarily Incident] Second, the license is one of several examples of OFAC explicitly authorizing a U.S. person (here the DOJ) to engage in a sale of blocked property, where it is implicit (or authorized as ordinarily incident to the explicit authorization) that the purchase of the property by a U.S. person (her LK...