31 CFR § 544.508 Payments for legal services from funds originating outside the United States.

Date issued: Feb. 15 2022

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TURBOFAC Commentary (158 words)

Notes common to all "Payments for legal services from funds originating outside the United States" provisions:

1) This provision, issued in 2014 or thereafter and common to many blocking based sanctions programs, should be read in conjunction with the GL for the provision of legal services. This provision includes a "fresh funds" requirement and unusual sort of reporting requirement that is not a license application but is nevertheless necessary to benefit from the license. Refer to Notes Common to most Versions of the "Provision of Legal Services" General License (System Ed. Note), also addressing the payments issue. By all appearances, payments for legal services, when not generally licensed, are subject to favorable licensing policies whether or not a given set of sanctions regulations explicitly contains a GL for legal service payments. As discussed in the system note referred to, payments from blocked...