License No. SDT-005; License No. SDT-009

Date issued: Aug. 31 1998

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TURBOFAC Commentary (731 words)

Notes:

1) See p. 28 of the native pdf file for the licenses. The sanctioned person at issue here was a U.S. citizen residing in the U.S. (see p. 1) who was designated in 1995 as a SDT pursuant to the IEEPA-based, now-repealed Terrorism Sanctions Regulations for providing support to Hamas. At the time of the designation, neither the AEDPA (1996) nor the FTOSR (1997) had come into being. Hamas was designated as an FTO on October 8, 1997, concurrent with the issuance of the FTOSR. The licenses at issue here were issued in 1998.

2) From a technical standpoint, the licenses are notable for its citation of both IEEPA and the AEDPA as...