License No. SY-2014-307676-1

Date issued: Nov. 07 2014

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TURBOFAC Commentary (216 words)

Notes:

1) License issued to unblock funds the subject of a writ of attachment pursuant to TRIA. See Wyatt et al v. Syrian Arab Republic - U.S. Statement of Interest, and comments thereto.

These funds were duly blocked at the time of the initial blocking, as the Syrian Government sought to pay U.S. counsel without first having obtained the required specific license (542.507). This constitutes a rare situation in which OFAC issues a discretionary license for the “dissipation” of blocked funds that were duly blocked at the outset and were the property of persons still blocked at the time the license was issued.

From a licensing policy perspective, it is not clear whether the rationale behind issuing the license was that the payment would have probably been specifically licensed if a license were...