Rubin v. Harvard University, 11-2144 (1st Cir. 2013) - OFAC/Treasury Amicus Brief

Date issued: Jun. 07 2012

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TURBOFAC Commentary (445 words)

Notes:

1) The government/OFAC opine that property can be within the scope 535.201 and not constitute a "blocked asset of" the Government of Iran for TRIA purposes. As discussed below, the difference between "property of" a government for TRIA purposes and property "in which" the government has an "interest" for blocking purposes has been made in various other cases.

2) The implication of OFAC's arguments are that the transfer directives of the IACR have no ‘expiration date.’ Iran may assert claims to property initially blocked pursuant to the IACR at any time, and U.S. persons are subject to the transfer obligations, even today, subject to the proviso that the GOI have uncontested and non-contingent ownership in the property. See Rubin v. Islamic Republic of Iran 830 F.3d 470 (7th...