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Price Benowitz’s OFAC Law Group successfully obtained an OFAC unblocking license for a client whose personal funds were blocked due to an intermediary financial institution’s false positive match to the Specially Designated Nationals List. The client’s name resembled a person on the SDN list and the funds were blocked due to a lack of timely communication with the bank and related compliance concerns. A specific license to unblock the funds authorizes the financial institution to return the funds to our client.
The OFAC Law Group was granted an OFAC specific license to obtain payment from an SDN client. The payment structure fell outside of the authorization of the general license to receive legal fee payments from an SDN person. Law firms must review the limitations of relevant authorizations to receive payment from SDN persons. SDN list removal is an extensive and complex process. Lawyers may need to obtain a specific license from OFAC prior to receiving payment from their client.
While the defendants did not admit any fault, we are happy to report that PAE agreed to pay the United States $5,000,000 to resolve the False Claims Act allegations contained in Mr. Palombo’s Complaint.