LICENSE No. UKRAINE-EO13660-2016-326950-1, LICENSE No. UKRAINE-EO13660-2016-326950-2 [Applications Included in Original PDF]

Date issued: Mar. 02 2016

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TURBOFAC Commentary (458 words)

Notes:

1) This license request, and the issuance of the license, were made subsequent to and as a result of the guidance provided in Case No. UKRAINE-EO13660-2015-323659-1 (see comments thereto for further background on this case in general). That guidance letter stated that while counsel for the U.S. claimant did not require a license from OFAC to engage in a U.S.-based commercial arbitration against a blocked party, U.S. counsel for the blocked party and the U.S. arbitrator did.

2) With the first license (application attached), OFAC authorized all persons participating in the arbitration "to engage in all transactions that are necessary and ordinarily incident to the hearing presided over by [the arbitrator]." Subsequent to the issue of that license, there was a need for a time extension and, in addition, a question of whether the issuance of the final enforceable award—as opposed...