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License No. SDGT-2020-367813-1
GLOBAL TERRORISM SANCTIONS REGULATIONS
LICENSE
(Granted under the authority of one or more of 50 U.S.C. §§ 1601-51, 1701-06, 22 U.S.C. § 287c, Executive Order 13224 as amended, and 31 C.F.R. parts 501 and 594.)
To: U.S. Department of Justice
U.S. Attorney’s Office for the District of Columbia
555 Fourth Street, N.W.
Washington, D.C. 20530
Attn: Zia M. Faruqui
1. Based on your request dated July 5, 2020, and additional correspondence dated July 12, 2020, and information otherwise available to the Office of Foreign Assets Control (the “Application”), the transactions described herein are hereby authorized.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and with all regulations, rulings, orders, and instructions issued under...
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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...