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LICENSE No. FNK-2017-341112-2
FOREIGN NARCOTICS KINGPIN SANCTIONS REGULATIONS
AMENDED LICENSE
(Issued under the authority of one or more of the Foreign Narcotics Kingpin Designation Act, 21 U.S.C. §§ 1901-07, and 31 C.F.R. Parts 501 and 598.)
To: Archer & Greiner, P.C.
Three Logan Square
1717 Arch Street, Suite 3500
Philadelphia, PA 19103
Attn: Jeffrey M. Kolansky
1. Based upon your request dated October 19, 2018, to the Office of Foreign Assets Control (the “Application”), and information otherwise available to the Office of Foreign Assets Control, the transactions described herein are hereby authorized. This License supersedes License No. FNK-2017-341112-1 in all respects.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and with all regulations, rulings, orders, and instructions issued...
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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...