LICENSE No. IA-2013-303215-1

Date issued: Jul. 24 2013

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TURBOFAC Commentary (705 words)

Notes:

This is a one-off, one-of-a-kind specific license insofar as it was issued to effect the unblocking of funds envisaged by 22 U.S.C. §8701, et seq. of the Iran Threat Reduction and Syria Human Rights Act (TRA), of which § 8772 refers explicitly to the blocked assets described in the specific license and makes them subject to turnover. Note that the judicial orders referred to in the specific license are included in the native PDF file.

1) UNUSUAL SPECIFIC LICENSE NOTWITHSTANDING A PROVISION THAT APPEARS TO STRIP OFAC OF JURISDICTION OVER THE FUND AT ISSUE

As it relates to the scope and operation of OFAC-administered sanctions laws, the license is notable for two reasons in particular. One is that it exists in the first place. 22 U.S.C. § 8772 of the