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LICENSE No. UKRAINE-EO13660-2016-328924-1
LICENSE
UKRAINE-RELATED SANCTIONS REGULATIONS
(Granted under the authority of one or more of 50 U.S.C. 55 1701-05. 50 U.S.C. 55 1601-51, Executive Orders 13660, 13661, 13662, and 13685 and 31 C.F.R. Parts 501 and 589.)
To: Weil, Gotshal & Manges LLP
co DLA Piper LLP (US)
500 8th Street, NW
Washington, DC 20004
Attn.: Richard Newcomb, Esq.
1. Pursuant to your request dated April 22, 2016 submitted on behalf of Weil, Gotshal & Manges LLP and Forbes Media LLC, as well as your letters of March 2, 2016 and March 15, 2016 submitted pursuant to Case Numbers UKRAINE-EO13660-2016-326950-1 and UKRAINE-EO13660-2016-326950-2, as well as your letters of October 26, 2015 and December 18, 2015, submitted pursuant to Case Number UKRAINE-EO13660-2015-323659-1, to the Office of Foreign Assets Control (collectively, the...
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1) Third of three applications/OFAC responses issued in connection with the same case; see (a) Case No. UKRAINE-EO13660-2015-323659-1 and (b) LICENSE No. UKRAINE-EO13660-2016-326950-1, LICENSE No. UKRAINE-EO13660-2016-326950-2, and comments thereto, for more background.
2) This license and application (attached in native PDF file) were drafted subsequent to the issuance of the final arbitral award, issued under OFAC license. While LICENSE No. UKRAINE EO13660-2016-326950-2 makes clear that the issuance of a final arbitral award is a transaction ordinarily incident to the arbitral hearing itself, OFAC, in issuing this license, appears to not view the actual enforcement of the arbitral award to be incident to the underlying arbitration. Such enforcement is clearly excluded in the WARNINGS section of the LICENSE No. UKRAINE EO13660-2016-326950-2 that excluded from the scope of the license "the entry of any judgment or order that effects a transfer of blocked property, or the execution...