Civil Enforcement Information - Park Strategies, LLC

Date issued: Jan. 21 2020

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TURBOFAC Commentary (438 words)

Notes:

1) THE SCOPE OF THE BOILERPLATE LEGAL SERVICES GENERAL LICENSE

The enforcement action web post outlines the scope of the boilerplate general license for the provision of "legal services" in a manner that generally confirms the reading taken in Case No. SU-3937, especially with regard to lobbying services being outside of the scope of the GL. In this case, OFAC highlighted that “Park Strategies was not a law firm at the time of the Apparent Violations,” but even if it were, OFAC has taken the position that the provision of lobbying or other public relations services by a lawyer is not within the scope of the boilerplate language of the GL for legal services – even when such lobbying services are at least arguably part and parcel of certain forms of legal representation (see again Case No. SU-3937)....