License No. lA-2021-376547-1; License No. IA-2021-376893-1

Date issued: Jul. 06 2021

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TURBOFAC Commentary (338 words)

Notes:

1) The two licenses at issue unblock funds that were blocked by Stripe, acting as an intermediary bank processing an Iran-related transaction. The underlying facts (see native PDF) appear to be as follows: an Australian citizen and son of a person imprisoned at an SDN Iranian prison raised funds online to help pay Iranian “court costs” to help free the prisoner. Stripe was the payment processor for the online donation site. The USD amounts seen in the two licenses represent the $150 and $100 AUD seen on p. 6 of the native .pdf file.

The blocked amounts at issue here were practically de minimis, but the unblocking licenses serve as a rare example of OFAC unblocking funds in which a blocked person has an “interest”, where such unblocking is not otherwise envisaged by a written licensing policy (see...