LICENSE No. DABRESERVES-EO-2022-886895-1

Date issued: Feb. 11 2022

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TURBOFAC Commentary (2245 words)

Notes:

1) BACKGROUND

This license, Executive Order on Protecting Certain Property of Da Afghanistan Bank for the Benefit of the People of Afghanistan (EO 14064), and In Re: Terrorist Attacks on September 11, 2001 (1:03-md-01570) (Dkt. 7661) - USG Statement of Interest (the SOI) were all issued on the same day (Feb. 11, 2022).

As discussed in Temporary Note Concerning the Status of the Unrecognized Government of Afghanistan Under the GTSR, OFAC had, from the time at which the Taliban assumed de facto control over the Government of Afghanistan up through at least 2/11/22, been strategically silent on the question of whether the Taliban, an entity blocked pursuant to the GTSR, had an “interest” in all property of the Government of Afghanistan and its various ministries...