Case No. SDGT-1432; LICENSE No. SDGT-1432 [Application included]

Date issued: Aug. 04 2010

Last substantive commentary amendment:
Oct. 05 2024

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TURBOFAC Commentary (812 words)

Notes:

1) Even for the most sensitive SDNs, U.S. persons may represent either them or their representatives without "any requirement that the individual contact OFAC or apply to OFAC for a license." Yet OFAC issues a license in which the authorization section itself provides that it is being granted "to the extent authorization is necessary."

The context of this was a contemplated lawsuit against the government by the father of a U.S. citizen SDGT living abroad that was revealed to have been placed on a CIA "kill list." The contemplated lawsuit sought to have him removed from the list. [1] (He was eventually killed by a U.S. drone subsequent to the issue of this license).

This cover letter interprets a version of 594.506...