LICENSE No. FNK-2017-341112-2

Date issued: Oct. 30 2018

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TURBOFAC Commentary (148 words)

Notes:

1) Compare 598.511, which is a FNKSR GL, issued in May of 2021, that authorizes "Certain transactions for the expenses of maintaining blocked tangible property". It is unclear whether real property is included within the scope of "tangible property" as it appears in the new GL, but this license suggests that OFAC's licensing policy toward the management and maintenance of blocked real property is a favorable one.

2) Given that a Licensee is SDN's law firm, it seems clear that the activities authorized are outside the scope of those authorized by the standard "legal services" GL (598.507).

3) Related licenses:

(i) LICENSE No. FNK-2017-340718-1, (ii) LICENSE No. FNK-2017-341112-2...