OFAC Interpretive Guidance/Licenses - Review of U.S. Treasury Department’s License to Convert Iranian Assets Using the U.S. Financial System” – Majority Report of the Senate Permanent Subcommittee on Investigations

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TURBOFAC Commentary (5463 words)

Notes:

The "Extinction of Interest" Concept, "Indirect Exports of Financial Services" and the Senate Majority Report of the Senate Permanent Subcommittee on Investigations on OFAC’s License to Convert Iranian Assets Using the U.S. Financial System; and Associated interpretive Guidance.

In this commentary we explain that, while the Senate Report omits discussion of the issue, some of the interpretive guidance issued by OFAC that the report refers to was almost certainly an application of the "comes to rest"/"extinction of interest" principle seen in Case No. IA-[REDACTED] (Patton Boggs LLP), Jan 5, 2011) and Case No. IA-2012-(Chicagoland Foreign Investment Group, LLC), except applied with what may be a far more significant effect. We are in the process of seeking certain of the underlying documents referred to in the report via FOIA.

Essentially, it appears as though OFAC acknowledged that the Central Bank of Iran...

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Review of U.S. Treasury Department’s License to Convert Iranian Assets Using the U.S. Financial System” – Majority Report of the Senate Permanent Subcommittee on Investigations

TURBOFAC Commentary (5463 words)