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 (3169 words)

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

1) BACKGROUND

The context of the specific license (pp. 1-2 of the PDF file) is one of the U.S. government's many recent forfeiture actions focusing on property related to offshore USD-denominated oil and oil tanker-related purchases that entail sanctions violations. Here, the USG sought—and as of 8/9/2021 is still seeking—to forfeit (i) blocked funds connected to an offshore purchase of a vessel by an Iranian front company, and (ii) the vessel itself.

At the same time, certain private citizens holding TRIA-based judgments against the GOI were/are seeking to attach the frozen funds that are the subject of the USG’s forfeiture action. See...