CASE No. SDNT-257 [Application included]

Date issued: Jan. 27 2005

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TURBOFAC Commentary (470 words)

Notes:

1) While dated, this license denial letter is notable for two reasons. The letter interprets a restriction that is common in modern general licenses for the receipt of payments for legal services (see e.g. 536.507 of the NTSR, which was not in effect at the time this letter was drafted). 536.507, similar to the specific license referenced here, provides that: “[r]eceipt of payment of professional fees and reimbursement of incurred expenses for the provision of legal services authorized pursuant to §536.506(a) to or on behalf of a specially designated narcotics trafficker is authorized from funds originating outside the United States, provided that the funds do not originate from…source within the United States…Any source, wherever located, within the possession or control of a U.S. person; or…Any individual or entity, other than the person on whose behalf the legal services...