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Case No. SY-2019-360387-1
Enrique D. Zamora, Esq.
Zamora Hillman & Villavicencio
3006 Aviation Avenue, PH-4C
Coconut Grove, FL 33133
Dear Mr. Zamora:
This responds to your request dated March 26, 2019 and the April 22, 2019, August 10, 2019, and August 29, 2019 supplements (collectively, the “Application”) to the Office of Foreign Assets Control (OFAC) for authorization to distribute $20,797.25 from the late Adib A. Akkary’s estate to ten [1] Syrian nationals resident in Syria. You state in the Application that you were appointed to oversee the distributions by a Florida Circuit Court and were ordered by the court to send the distributions. You further state that none of the Syrian beneficiaries appears on the Specially Designated Nationals and Blocked Persons List. In addition, you provide affidavits from several of the beneficiaries indicating the...
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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...