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LICENSE No. FNK-2015-323572-1
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SECTION I – AUTHORIZATION: Subject to the conditions and limitations stated herein, Yani Benjamin Rosenthal Hidalgo, designated pursuant to the Foreign Narcotics Kingpin Designation Act, is hereby authorized to engage in all transactions necessary to:
(a) purchase, make payment for, and receive goods, services, and funds essential to the maintenance of the Licensee and his family members, including food, clothing, housing, medical care, educational expenses, transportation, insurance, and utilities; and
(b) establish and maintain an account with a U.S. financial institution for the purpose of carrying out the transactions authorized in Section I(a).
SECTION II – WARNINGS: (a) This License does not authorize the transfer of any blocked property, the debiting of any blocked account, the entry of any judgment or order that effects a transfer of blocked property, or the execution of any judgment...
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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."