§594.517 Payments from funds originating outside the United States and the formation of legal defense funds authorized.
(a) Payments from funds originating outside the United States. Effective December 7, 2010, receipts of payment of professional fees and reimbursement of incurred expenses for the provision of legal services authorized pursuant to §594.506(a) are authorized from funds originating outside the United States, provided that:
(1) Prior to receiving payment for legal services authorized pursuant to §594.506(a) rendered to persons whose property and interests in property are blocked pursuant to §594.201(a), the U.S. person that is an attorney, law firm, or legal services organization provides to the Office of Foreign Assets Control a copy of a letter of engagement or a letter of intent to engage specifying the services to be performed and signed by the individual to whom such services are to be provided or, where services are to be...
These three provisions were all added to the CFR on the same day, and are substantively identical apart from the fact that the version for the FTOSR--which is an irregular sanctions program transposed directly from the AEDPA--is drafted so as to account for the fact that the FTOSR only pertains to financial institutions.
Subsection (a) of these provisions is substantively identical to a handful of analogous provisions from other sanctions programs titled "Payments for legal services from funds outside the United States authorized" (see e.g. §541.508).
The provision should be read in conjunction with the GL for the provision of legal services. This provision includes a "fresh funds"...