Case No. SDGT-816a, LICENSE No. SDGT-816a, LICENSE No. SDGT-957, LICENSE No. SDGT-816b, Case No. SDGT-816c

Date issued: Mar. 04 2010

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TURBOFAC Commentary (429 words)

Notes:

1) The materials here are notable as an application and interpretation of OFAC's Guidance on the Release of Limited Amounts of Blocked Funds for Payment of Legal Fees and Costs Incurred in Challenging the Blocking of U.S. Persons in Administrative or Civil Proceedings (Legal Fee Guidance). Case No. SDGT-816a, LICENSE No. SDGT-816a and LICENSE No. SDGT-957 were evidently issued concurrent with the initial adoption of the “Legal Fee Guidance” policy (though prior to OFAC having generally licensed, in Dec. of 2010, the receipt of fresh funds from blocked persons and establishment of a legal defense fund for the provision of legal services -- §594.517).

The last paragraph of the Legal Fee Guidance provides as follows:

As a prerequisite for receiving a specific license, a Blocked...