DEPARTMENT OF THE TRE:.

ASURY

WASHINGTON

FAC No.

Dear Mr. Krislov:

On December 10, 1986, your client, Victor Azrak, resident in Panama, was included on the list of Spec~ally Designated Nationals of Cuba published in the Federal Register (51 FR 44459). Subsequently, you petitioned th~s office for removal of your client from the list of Specially Designated Nationals of Cuba ("Cuban SDN's"). You have also provided documentation in support of this petition, including detailed information on the nature of your client's business dealings with Cuba and verification that he no longer holds any interest in or control over two Panamanian companies, Azrak, S.A., and Famesa International, S.A., which were also included in the above list of Cuban SDN's.

You have been provided with a copy of proposed "General Terms for Removal from the SDN List" for your review. It is our understanding that your client is prepared to agree to these terms. Therefore, please advise your client that he must sign the enclosed "Terms of Removal" before a notary public or similar official authorized to authenticate a document and return the original of that completed agreement to this office. It would expedite matters if we were provided with a copy of the signed agreement by facsimile transmission as soon as it is completed (FAX: 202-376-1435). Upon receipt of the signed agreement, we will take the necessary steps to remove your client from·the list. Removal will be effected through a short notice published in the Federal Register. You will be provided with a copy of the notice upon publication.

The Office of Foreign Assets Control reserves its authority under the Cuban Assets control Regulations (3l CFR Part 515) to designate any person as a Specially Designated National of Cuba in the event that we have reason .to bglieve that such person is acting in a manner that brings it within the scope of that term as defined in the Regulations (31 CFR Part 515, Sec. 306). Therefore, in agreeing to the enclosed "Term~ of Removal," your client must understand .that failure to adhere to these terms could result in a subsequent special designation as we determine to be appropriate.

It is understood that nothing in the "Terms of Removal" shall preclude your client from selling non-U.S. goods, products or services to Cuba provided no other term of the agreement is

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LCCR Q & R - 004032

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violated, and provided that any such activity is not conducted on a scale that would lead us to reasonably believe that he is acting for or on ·behalf or under the direction or control of Cuba.

We look forward to the final resolution of this matter. If you have any questions or comments, please do not hesitate to call me (202-376-0395) or Mr. David Vogt (2D2-376-4786).

Sincerely,

R. Richard Newcomb Director

Office of Foreign Assets Control

Mr. Moses Krislov

Moses Krislov Co., L.P.A. Suite 800, Standard Building 1370 ontario Street Cleveland, OH 44113

Attachment

LCCR Q & R - 004033

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DEPARTMENT OF THE TREASURY WASHINGTON, D.C. 20220

I (b )(2)

FACNo.

JUL 1 9 2005

Victor E. Azrak

I{b )(6) & (b )(7)(C)

Panama, Republic of Panama

Dear Mr. Azrak:

This letter informs you that effective on the date of this letter, AZRAK S.A., Panama [CUBA] is no longer a Specially Designated National of Cuba pursuant to the Cuban Assets Control Regulations, 31 CFR Part 515. All lawful transactions between U.S. persons and the entity that were previously barred by the designation are now perrnissib I e.

A notice of this removal from the list of Specially Designated Nationals will appear on the Office of Foreign Assets Control's website shortly and will also be published in the Federal Register.

Sincerely,

~du/cJ. ~

Robert W. Werner . Director

Office of Foreign Assets Control

cc:

l(b)(6) & (b)(7)(C)

tees Q & R - 004034

All redactions on this page made pursuant to (b )(6) & (b )(7)C) unless 'otherwise indicated

'Member

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November 21, 2004

I(b )(2)

OFACNo._

Office of Foreign Assets Control Department of The Treasury

ATTN: International Programs Division 1500 Pennsylvania Avenue NW Washington D.C. 20220

RE: Azrak S.A.

Dear Mr. McBrien

The Azrak family has again encountered a problem as a result of the confusion between their name and the above defunct entity. The family wants to begin a banking relationship with Citi Bank, but the confusion with the above defunct company is causing a delay.

On August 16th the information that was requested in connection with removing the above named entity from the List of Specially Designated Nationals (Cuba) was sent to your office. Please advise me of the status of this matter.

Thank you.

Very truly yours,

, .

LCCR Q & R - 004035

All redactions on this page made pursuant to exemptions (b)(6) & (b)(7)(C) unless otherwise indicated

l(b)(2)

August 3<d, 2004.

Re: FACNo._

Office of Foreign Assets Control Department of the Treasury

ATTN: I nternational Programs Division 1500 Pennsylvania Avenue NW Washington, DC 20220

Dear Mr. McBrien:

In connection with my request to have Azrak SA removed from the list of Specially Designated Nationals of Cuba and pursuant to your request for pro sf that the above company has been dissolved and has not been in business for many years, please find enclosed the following original documents in Spanish with English translation:

1. Certificate of Dissolution from the Public Registry of Panama.

2. Certificate from the Panamanian Social Security administration certifying that Azrak, SA's last payroll was in July 1986.

hope the above documents will enable you to remove Azrak, SA from the list of Specially DeSignated Nationals of Cuba so that my family and I will not continue to be adversely affected by its presence there.

Sincerely yours,

LCCR Q & R - 004036

'_ _'

All redactions on this page made pursuant to (b)(6) & (b){7)C)

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REPUBLICA DE PANAMA

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LCCR Q & R _ 004037

All redactions on this page made pursuant to exemptions (b }(6) & (b )(7)(C)

TRANSLATION REPU8LIC OF PANAMA PUBLIC REGISTRY OF PANAMA In view to the application -

THAT THE CORPORATION AZRAK, SA

CE R T I FIE S

is registered under Volume: 338, Folio 109, Entry 72024 of the Mercantile Section since the 4th of December nineteen hundred fifty seven, updated to Microjacket 4924, Roll 200, Frame 230, of the Microfilm Mercantile Section.

DISSOLVED.

That the Corporation has been dissolved.

ISSUED AND SIGNED IN THE PROVINCE OF PANAMA, THE 23'd DAY OF JUNE, TWO THOUSAND F.OUR, AT 09:52:55 AM.

NOTE: THIS CERTIFICATION HAS PAID THE STAMP TAX FOR A VALUE OF 8/.30.00 VOUCHER No. 717108

NO. CERTIFICATE S. ANONIMA 566856 DATE: Wednesday 23, June 2004

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CERTIFIER

SEAL OF THE PUBLIC REGISTRY OF THE REPUBLIC OF PANAMA

The undersigned, English Translator CERTIF INGles· "&PANOL

in Spanish. lI"AHoL .!HGlES

MS. Hr.

Panama, June 23, 2004

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Translator

LCCR Q & R - 004038

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All redactions on this page made pursuant to exemptions (b )(6) & (b )(7)(C) .

Apartado /393 Panama 1, Panama.

CASESO

Panama, 17 de mayo de 2004 .

A, ~~ii~1lli C@~&ii~i1]te.:

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A solicitud del interesado y para uso de tramite administrative, hacemos constar que para la empresa AZRAK, S. A" identificado bajo el mrmero patronal87-243-0023, la Ultima planilla reportada y cancelada en los conceptos obrero patronal fue el mes de julio de 1986.

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se debe dar Ie y creduos. Pwwmd.2( de __ ~~~ __

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tees Q & R - 004039

19/12 200~, 15: 21 fAX_

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@OOI

December 19. 2003

Mr. R. Richard Newcomb

Director Office of Foreign Assets Control U.S. Department of the Treasury

1500 Pennsylvania Ave. N.W. Washington D.C. 20220

U. S.A.

Dear Mr. Newcomb:

This is further to my telephone conversation with Ms. _ from the Compliance Division.

During the late spring and early summer of 1990 my petition to have myself removed from the list of Specially Designated Nationals (Cuba), culminated in my removal from the list pursuant to publication in the Federal RegisterNol 55, No. 148IWednesday, August 1, 1990 of an amendment to said list dated July 18, 1990.

A Panamanian corporation, Azrak S.A. was also supposed to be removed at the same time, but was inadvertently omitted. My attorney at that time, Moses Krislov, E~q·. -:.: how deceased - was informed that Azrak S. A. would be removed in the next amendment to the list. I had no ownership or other interest in Azrak S. A. as it was duly established by Mr. Krislov at that time. Still, I do not have any ownership or other interest in Azrak, S.A. Since 1988 Azrak S.A has been out of business. It is still out of business.

The continued presence of Azrak S.A. on the list periodically affects me and others who have the surname Azrak in a negative manner, Recently a funds transfer from the United Kingdom was held up for several days &IS a result of confusion caused by the continued presence of Azrak S.A. on the List.

Ms.~as kind enough to listen with keen interest to my detailed explanation of these circumstances. However, given the time elapsed since their occurrence, she suggested that I write a note to you, She promised 10 follow up the matter with you. This is why I am sending a copy of this letter to her attention.

Please remove Azrak S.A. from the List of Specially Designated Nationals (Cuba) so that me and my family do not continue to be adversely affected,

Thanks you,

'?4~7

Victor E. Azrak ..

c.c. _ - Compliance Division /'

teen Q & R - 004040