LICENSE No. IA-2012-298595-1
Executive Order 13628 — Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Threat Reduction and Syria Human Rights Act of 2012 and Additional Sanctions With Respect to Iran
LICENSE
(Granted under the authority of 22 U.S.C. §§ 8501-51, 8701-8785, 50 U.S.C. §§ 1601-51, 1701-06, 1701 note, and Executive Orders 12957 and 13628)
To: The Law Offices of Saeid B. Amini
730 24th Street, NW, Suite 1
Washington, DC 20037
Attn: Saeid B. Amini, Esq.
1. Based upon your requests dated November 16, 2012, and January 16, 2013, to the Office of Foreign Assets Control (the "Application"), the transactions and activities delineated herein are hereby authorized.
2. This License is granted upon the statements and representations...
1) All OFAC sanctions regulations involving blocked or otherwise sanctioned persons contain a version of a boilerplate "legal services" GL (see e.g. § 587.506 Provision of certain legal services). Seeing as that they are not framed as "TEAR" ("to the extent authorization is required") licenses, these GLs purport to assert jurisdiction over, among other things, "[r]epresentation of persons named as defendants in or otherwise made parties to legal, arbitration, or administrative proceedings before any U.S. federal, state, or local court or agency". Meanwhile, U.S. federal courts have held that (e.g.), while OFAC retains jurisdiction over the receipt of payments, "[OFAC] lacks authority...to condition the bare formation of an attorney-client relationship on advance government approval." (See section 2 of General Note Concerning Unlicensed Litigation Involving Sanctioned Persons or Property (System Ed. Note)). So, what happens when a blocked person...