shutterstock_115001698Part 1 of this post discussed the judgment creditors in Havlish v. bin Laden who are are trying to interdict assets owned by Iran.  Part 1 explained the judgment creditors sought to attach monies reportedly earmarked for the purchase of Airbus aircraft. Before seeking the attachment of the monies, the judgment creditors subpoenaed confidential information kept at U.S. Treasury’s Office of Foreign Assets Control (“OFAC”).  This confidential information could help the judgment creditors search for bank accounts or other assets Iran beneficially owns.

OFAC agreed to release the confidential information after the judgment creditors served OFAC with subpoenas & after the Court issued protective orders restricting the judgment creditors’ use of the information.  Via their subpoena dated March 2, 2015, the judgment creditors first requested confidential information about assets in the U.S. blocked at financial institutions because of economic sanctions against Iran.  This subpoena requested that OFAC provide the judgment creditors with the following:

[a]s of March 2, 2015, a list of all financial institutions holding assets in the United States that are blocked due to a nexus with the government of the Islamic Republic of Iran, its political subdivisions, and its agencies and instrumentalities, and the total such assets reported by each such institution, rounded to the nearest $100,000.

The judgment creditors next broadened their asset search by serving a May 17, 2015 subpoena on OFAC.  The May 17th subpoena requested seven categories of information from OFAC regarding: Iran’s financial accounts which had been frozen in Switzerland; financial accounts of Iran’s Mahan Air; financial accounts maintained by the Hezbollah, al Qaeda and Taliban terrorist groups; financial accounts at 3 banks in China; etc.  Click here to view the May 17th subpoena.

Image: Jim Vallee/

Copyright 2015-2018 Fred L. Abrams