CASE No. SDGT-999

Date issued: Aug. 21 2008

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TURBOFAC Commentary (132 words)

Notes:

1) Refer to Legal Fee Guidance, and comments thereto. The letter is generally straightforward, but does clarify two aspects of the application of the "Legal Fee Guidance". First, that "including the source(s) of payment" does not "require that [a specific license applicant] identify specific individuals who have provided the funds". "Source" evidently refers to country in that context. Second, the letter clarifies that the monetary caps being calculated based on two attorneys per case does not mean that more than two attorneys can work on a given case. "[T]he choice of which attorneys may be compensated under this policy is left to the discretion of the blocked party." In other guidance, OFAC has specified that the legal services GL applies to attorneys working pro bono. (CASE No.