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Dec 4, 2001
BLOCKING NOTICE
FAC No. SDGT-197443
Holy Land Foundation for Relief and Development
525 International Parkway
Richardson, Texas 75081
Gentlemen:
You are hereby notified that Holy Land Foundation for Relief and Development (Holy Land) has been designated pursuant to Presidential Executive Order No. 13224 (66FR49079), issued on September 23, 2001, and No. 12947, issued on January 23, 1995 (60FR5079) (the “Order”), and under the authorities granted by the international Emergency Economic Powers Act, 50 U.S.C. 1701-06 (“IEEPA”).
This notice is also to inform you that pursuant to the Orders, all real and personal property of Holy Land, including but not limited to all offices, furnishings, equipment and vehicles, as well as all funds and accounts in which Holy Land has any interest, are blocked. All assets of Holy...
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1) Blocking notice issued in connection with a U.S. government raid of the headquarters of an SDGT-designated, U.S.-person entity [1].
The following passage is notable:
All transactions involving property in which Holy Land has any interest, including any property of third parties in the possession or control of Holy Land, are prohibited without specific authorization from OFAC.
This is an articulation of the concept of a "possessory interest," which is a type of non-ownership "interest" within the scope of the basic blocking regulation.
The blocking of a person requires U.S. persons to physically block all property, in which a blocked person has an interest, that is within the "possession or control" of a U.S. person.
Here, OFAC construes the basic blocking prohibition such...