Case Nos. SDGT-444, SDGT-472 and SDGT-475; LICENSE No. SDGT-484 [Applications included]

Date issued: May. 12 2005

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TURBOFAC Commentary (159 words)

Notes:

1) Application and license start at p. 32 of the associated PDF file. The applicable regulations, as they existed at the time of the issuance of the license, can be found here. The applicant requests, prior to the issuance of the 2008 Legal Fee Guidance, a specific license for payment of legal fees from blocked funds. OFAC rejects the request, and instead issues a "fresh funds" license and, subsequent to that, a separate "legal defense fund" specific license (of the sort that, as of 2010, is the subject of the general license at 594.517 of the GTSR). Query: would the authorization at section 1(b) of the specific license describe activities implicitly authorized by the current GL as “ordinarily incident” to the creation of the defense fund? (“to transfer to the...