Related to 3907 3087833

The whole thing of "license" for taking care if the money as related to FMS Trust, Judgement Trust, and JCPOA.

Referring back to

https://www.portman.senate.gov/public/index.cfm?a=files.serve&File_id=32D41C7F-5D2F-43F3-BDE4-F532AC942BCB

Page 9/53 for OFAC issuing the specific license. OFAC

And pages 50,51, 52 of 53 for reference regarding access to US financial sysytem.

Jack Lew also had prepared tp if pressed on specific license that general would be used instead. See 47&48 of 53.

When looking all through the below

https://www.treasury.gov/resource-center/sanctions/CivPen/Pages/civpen-index2.aspx

https://www.treasury.gov/resource-center/sanctions/Pages/licensing.aspx

https://www.treasury.gov/resource-center/sanctions/Programs/Pages/iran.aspx

And trying to reconcile sanctions requested for the JCPOA and then the end run for getting money transferred may lead one to believe that…

The echo chamber

https://www.washingtonpost.com/blogs/right-turn/wp/2016/05/09/congress-time-to-hold-ben-rhodes-to-account/?utm_term=.ff75090d0c9f

Had congress convinced everything on the up and up and the hearings were for show in light of presumed authority of Treasury and State. License issued by OFAC. Civil penalties are plentiful for violations. No need for sanctions if you're going to end run.

Though I can't find the four reference, incarceration changed from 10 to not more than 20 via the hand of Barry.

If correct, the FRBNY by placing themselves in this morass have opened themselves to more investigation than they hoped on the basis she wouldn't lose.