LICENSE No. FNK-2015-323572-1

Date issued: Nov. 05 2015

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TURBOFAC Commentary (130 words)

Notes:

1) License at pp. 17-18 of native PDF file.

2) Refer to Case No. FNK-2016-327937-1, and comments thereto, for comments on the nature of and background concerning the license.

The license does not specify that it does not apply to funds within the possession of control of a U.S. person. Given that the SDN was in the U.S. when the license was granted, this would mean that he could not use his own funds located abroad. At the same time, however, all of the SDNs funds worldwide were "blocked property" excluded from the license as a result of the SDNs "control" over those funds. OFAC appears to resolve this issue by not considering the "U.S. person's" funds held abroad to be "blocked."