LICENSE No. RUSSIA-EO14024-2023-1076594-1 [Application included]

Date issued: Sep. 29 2023

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TURBOFAC Commentary (544 words)

Notes:

1) This license was issued in connection with a state court litigation in which a blocked person was a plaintiff and a non-sanctioned U.S. person with assets in the U.S. was a defendant. The blocked plaintiff moved to have the state court recognize a foreign (Russian) judgment issued in favor of the plaintiff against the defendant. The court (see pp. 27 et seq. of the native PDF) ruled, almost certainly incorrectly, that it was barred not only from enforcing the judgment, but merely from “recognizing” the judgment as valid. The court reasoned that “while recognition is technically distinct from enforcement, recognition here appears to be merely a procedural step towards enforcement,” which is true, but OFAC has long regarded the scope of the blocking prohibition triggering at specified steps, i.e. the point at which a court would be engaged in the “transfer” of property in which...