License No. SDGT-2020-367813-1 [Application included], License No. MUL-2022-367813-2

Date issued: Oct. 14 2022

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TURBOFAC Commentary (3268 words)

Consolidated Comment on LICENSE NO. SDGT-2020-367813-1 AND SDGT-17138 (BLOCKING NOTICES)

[10-4-25 Update - see Estate of Levin v. Wells Fargo Bank, N.A., No. 23-7080 (D.C. Cir. 2025), a notable TRIA case holding that the license at issue here did not take the funds at issue outside the scope of the term "blocked assets" for purposes of TRIA. Note in addition that the opinion clarified that, in the view of the court, this license authorized courts to issue forfeiture orders with respect to the subject funds (“it permits courts to enter orders in forfeiture proceedings respecting the Funds")].

1) BACKGROUND

The context of the specific license (pp. 1-2 of the PDF file) is one of the U.S....