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Case No. NPW-2014-310771-1
Daniel S. Ruzumna, Esq.
Patterson Belknap Webb & Tyler LLP
1133 Avenue of the Americas
New York, NY 10036-6710
Dear Mr. Ruzumna:
This responds to your request dated June 20, 2014 (the "Application"), on behalf of your clients, the Alavi Foundation (the "Foundation") and 650 Fifth Avenue Company ("Fifth Avenue Company"), to the Office of Foreign Assets Control (OFAC), seeking a license for the Foundation's Board of Directors and its employees to provide services to the Foundation and Fifth Avenue Company, and to receive compensation for and/or reimbursement of expenses.
As you are aware, the United States commenced In re 650 Fifth Avenue and Related Properties, No. 08-cv-10934 (SDNY), on December 17, 2008, seeking forfeiture of the office building located at 650 Fifth Avenue, New York, NY (the "Building") and related bank...
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1) For general background on the litigation to which this item and several others in the Research System pertain, see Background Note re: United States v. Alavi Found. (In re 650 Fifth Ave. & Related Props.) and Related Cases. The following assumes familiarity with that background.
2) "BLOCKED ASSETS" FOR TRIA PURPOSES
(i) In a TRIA/FSIA attachment proceeding focusing on GOI property forfeited to the government, this guidance letter, LICENSE No. NPW-448 and several third-party licenses filed under seal were offered for the proposition that, in OFAC's view, the property that was the subject of LICENSE No. NPW-448 was "unblocked" for TRIA attachment purposes.
Note OFAC's view that, "[w]hen assets are subject to forfeiture pursuant to an OFAC license exempting them from...