Case No. SDGT-1432; LICENSE No. SDGT-1432

Date issued: Aug. 04 2010

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TURBOFAC Commentary (754 words)

Notes:

1) On the basis of the cover letter and license included in the PDF file, it is not easy to discern why the license issued was needed. 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...