OFAC Guidance - Legal Fee Guidance (2010)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (366 words)

Notes:

1) This guidance applies cross-programmatically, and is directly referred to in the notes to the general licenses for the provision of certain legal services (see e.g. 542.507).

2) This guidance/policy was initially made public on 07/21/2008. It was amended on July 23, 2010 to add footnote 2.

3) Concerning the reference to the "OFAC's policies allowing for the issuance of specific licenses for a Blocked Party to receive fresh funds from unblocked sources outside the United States and to raise funds in the United States through an authorized legal defense fund," note that since the release of this guidance OFAC has generally authorized the receipt of payments from fresh funds in many programs, and has generally authorized "legal defense funds" in others (see, 595.515, 597.513 and 594.517).

4) On the...

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Guidance on the Release of Limited Amounts of Blocked Funds for Payment of Legal Fees and Costs Incurred in Challenging the Blocking of U.S. Persons in Administrative or Civil Proceedings (Legal Fee Guidance) ​(2010)

TURBOFAC Commentary (366 words)

Guidance on the Release of Limited Amounts of Blocked Funds for Payment of Legal Fees and Costs Incurred in Challenging the Blocking of U.S. Persons in Administrative or Civil Proceedings (Legal Fee Guidance) (2010)