Estate of Levin v. Wells Fargo Bank, N.A., No. 23-7080 (D.C. Cir. 2025)

Date issued: Sep. 26 2025

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (185 words)

Notes:

1) This extremely consequential D.C. Circuit opinion deals with the funds that were the subject of License No. MUL-2022-367813-1, 2, and breaks with the law of other circuits in holding that the issuance of forfeiture licenses by OFAC to the DOJ does not take funds outside the scope of those that can be attached and turned over pursuant to the Terrorism Risk Insurance Act. The license at issue kept the funds blocked except insofar as a “valid forfeiture order” was obtained. The court rejected the argument that an “OFAC license authorizing any use unfreezes otherwise blocked funds.” Other circuits (opinions of which are cited by the Court here) had held that OFAC issuance of limited-scope specific license for the forfeiture of funds takes such funds outside the scope of “blocked assets” for