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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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[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....