Case No. SY-2019-360387-1

Date issued: Nov. 17 2020

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TURBOFAC Commentary (2851 words)

Notes:

1) BACKGROUND

This guidance letter relates to the probate of an estate of a non-U.S. person decedent who, at the time of his death in Syria, was (according to filings) “domiciled in Barbados” (p. 3, PDF). The surviving spouse of the decedent, also domiciled in Barbados, was the “personal representative” of the state for the purposes of the Florida probate action. The Florida probate action dealt with Certificate of deposit held in a U.S. bank. (Id). Of their heirs to the estate, 10 were resident in Syria, and six were resident in Venezuela (p. 11). While the personal representative had her own U.S. lawyer, the Florida court appointed an “Attorney Ad Litem” to ensure that OFAC regulations did not prohibit the making of the distributions to the individuals resident in Syria. This entailed the Attorney Ad Litem requesting guidance from OFAC (concerning both the Syria...