I spoke to OFAC today. The lady that wrote the letter said to me that even though she wrote the letter, it is not what she meant. That’s unacceptable. The letter clearly says that the vehicles have been released from detention. I will wait for Sean Kane to respond. If they don’t act, I recommend going to court. From: Haytham Faraj [mailto:Haytham@puckettfaraj.com] Dear Mr. Kane, I am writing because I believe based on a conversation I had today with OFAC enforcement officer Ms. Rachel Vaughn (sp), I need to provide some clarification regarding my petition for a license application that I communicated to you on June 23, 2011. Our petition seeks licenses to release all vehicles belonging to our clients that are currently blocked. Eventually the vehicles we will be sold transferred or exported. We cannot provide you information, at this time, about whom the vehicles will be sold to or if any will be exported because the original buyers may no longer purchase the vehicles. Once our clients are notified that licenses will be issued, I will begin to provide the information necessary to effectuate issuance of the licenses, should that information be necessary. Keep in mind that all our clients are prepared to provide written assurances that they will not engage Ellissa’ services in any future transactions. Also, It is my understanding based on the Treasury letter dated May 20, 2011 (ENF 23477), that “OFAC is authorizing CBP to release from detention any vehicle that is being held as blocked property pursuant to the Regulations as a result of the designation described above.” (Emphasis added). The letter goes on to say, in the same paragraph “However, these vehicles remain blocked and cannot be sold, transferred, exported, or otherwise dealt in without additional authorization, in the form of a license, from OFAC.” (Emphasis in original). The text of the paragraph makes clear that while the vehicles remain blocked, OFAC has authorized CBP to release the vehicles from detention. I request that you please provide notice to the various CBP officers at the port authorities that the vehicles are released from detention and may be retrieved by the owners are of the vehicles so long as they acknowledge that they may not sell, transfer, export or otherwise deal in the blocked vehicles. I am prepared to provide the necessary information regarding where the vehicles will be held pending final action by OFAC. Some of the vehicle owners will keep their vehicles at the ports because they do not have storage facilities; others will remove their vehicles to reduce the costs paid to store the vehicles. I appreciate your attention to this matter and look forward to your response Haytham Faraj, Esq. PUCKETT & FARAJ, PC _______________________ WASHINGTON DC METRO The Law Firm of Puckett & Faraj, PC 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone 202-280-1039 Fax DETROIT METRO The Law Firm of Puckett & Faraj, PC 313-457-1390 Phone 202-280-1039 Fax The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. |