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Case Nos. SDGT-444, SDGT-472 and SDGT-475
Shereef H. Akeel
Akeel & Valentine, PLC
401 S. Old Woodward, Suite 430
Binningham, MI 48009
Dear Mr. Akeel:
MAR 30 2005
This responds to your correspondence of January 12, 2005, February 22, 2005 and March 9, 2005, on behalf of the Islamic American Relief Agency and Melamed, Dailey & Akeel, P.C. or Akeel & Valentine, PLC, sent to the Office of Foreign Assets Control ("OFAC").
On November 24, 2004 Melamed, Dailey & Akeel, P.C. was issued License No. SDGT-403, which authorized the firm to receive, from nonblocked assets (also referred to as "fresh funds") of the IARA, payment for legal fees and reimbursement of incurred expenses for the provision of certain legal services to the Islamic American Relief Agency ("IARA"). As stated in OFAC's...
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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...