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GUIDANCE ON THE RELEASE OF LIMITED AMOUNTS OF …

DEPARTMENT OF THE TREASURY. WASHINGTON, 20220. OFFICE OF FOREIGN ASSETS CONTROL. GUIDANCE ON THE RELEASE OF LIMITED AMOUNTS . OF BLOCKED FUNDS FOR PAYMENT OF LEGAL FEES AND COSTS. INCURRED IN CHALLENGING THE BLOCKING OF PERSONS. IN ADMINISTRATIVE OR CIVIL PROCEEDINGS. This policy provides for the issuance of specific licenses, on a case-by-case basis, to authorize the RELEASE of a LIMITED amount of blocked funds for the payment of legal fees and costs incurred in seeking administrative reconsideration or judicial review of the designation of a person or the blocking of the property and interests in property of a person under the authority of Executive orders and regulations administered by OFAC (any such person hereinafter referred to as a "Blocked Party"), where alternative funding sources are not available. Pursuant to this policy, the blocked funds from which payment is sought must be legally and beneficially owned by the Blocked Party.

release of a limited amount of blocked funds for the payment of legal fees and costs incurred in seeking administrative reconsideration orjudicial review ofthe designation ofa U.S. person or the blocking ofthe property and interests in property ofa u.s. person under the authority ofExecutive

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