LICENSE No. FNK-2016-327876-1 [Application included in PDF]

Date issued: May. 27 2016

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TURBOFAC Commentary (829 words)

Consolidated Comment on LICENSE No. FNK-2016-327876-1, LICENSE No. FNK-2016-327886-1, LICENSE No. FNK-2016-327878-1 and LICENSE No. FNK-2016-327877-1

1) For general background on the case to which these licenses pertain, see the first part of the comments to Case No. FNK-2015-324389-1. In short, a non-U.S. citizen prisoner in the U.S. (Yankel Rosentha or “YR”) incurred millions of dollars’ worth of legal fees, and had certain assets located outside the U.S. and certain blocked assets within the U.S.

2) TIMELINE

Over the course of the prosecution against him, OFAC declined to unblock frozen funds in which YR had an interest, though OFAC issued certain specific licenses to facilitate legal service payments (“legal defense fund” license at LICENSE No. FNK-2015-324732-1; LICENSE No. FNK-2015-324732-2).

On March...