Bank of New York v. Rubin, No. 05 CIV. 4926 (DLC) (S.D.N.Y., 2005) - OFAC Director's Declaration; Misc. Specific Licenses (License No. IA-3579; License No. IA-3636)

Date issued: Dec. 01 2005

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TURBOFAC Commentary (272 words)

Notes:

1) This Declaration (P. 89 of PDF file) of the former OFAC Director, in the context of an attachment case, provides a useful overview of the scope and current practical operation of the IACR. (Compare General Note on the Continued Relevance of the IACR, its relationship to the ITSR, and the Occasional Usefulness of OFAC Amicus Briefs in ICAR-Related Litigation). The ITR, as they existed as of the time of the Declaration, can be found here. Note that the Declaration was drafted prior to the issuance of EO 13599, which blocked all property of the Government of Iran and Iranian financial institutions.

2) Note the...