Case No. FNK-2016-327936-1

Date issued: Apr. 01 2016

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TURBOFAC Commentary (663 words)

Notes:

[Update: on May 17, 2021, the FNKSR were modernized to bring its text in line with that of the typical set of blocking regulations. The change was non-substantive. See comments to 598.202. The below has not been amended to reflect the May 17, 2021 amendments to the FNKSR]

1) For general background on the case to which this guidance pertains, see the first part of the comments to Case No. FNK-2015-324389-1.

2) This letter was issued concurrently with Case No. FNK-2016-327937-1, concerning the applicant's co-defendant family member. With the exceptions discussed below, that guidance is virtually identical in substance to this one and addresses the same underlying issues, in particular the restriction on the use of blocked funds and funds of SDNs other than the client to pay legal fees. See comments...