License No. FNK-2015-316677-1

Date issued: Mar. 31 2015

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TURBOFAC Commentary (276 words)

Notes:

1) Compare License No. lA-2021-376547-1; License No. IA-2021-376893-1 and License No. SY-2014-307676-1 (similar wire transfer-related licenses). In some of these cases the financial institution is "is authorized to process the transfer in accordance with the original payment instructions" (License No. SY-2014-307676-1), and in others it is "authorized to return the funds lo the originator or originating financial institution" (License No. lA-2021-376547-1; License No. IA-2021-376893-1). Query whether the difference depends on whether the stopped wire was duly blocked to begin with. In License No. SY-2014-307676-1, the payment was, initially, duly blocked. Facts surrounding this case can be found at https://www.diariocolatino.com/departamento-del-tesoro-de-los-estados-unidos-autoriza-operaciones-comerciales-de-gumarsal/. This appears to be a case in which the funds were initially blocked due to a suspicion that the entity at issue was a front company for a