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Askan Holdings Ltd. v. United States Department of the Treasury, Office of Foreign Assets Control

Citation: Not availableDocket: Civil Action No. 2020-1458

Court: District Court, District of Columbia; September 23, 2021; Federal District Court

Original Court Document: View Document

Narrative Opinion Summary

This case involves Askan Holdings, Ltd.'s contestation of the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) decision to block funds related to a transaction involving an Airbus A320. Askan initially alleged violations of the Administrative Procedure Act and the Fifth Amendment, after OFAC's intervention due to national security concerns related to a specially designated global terrorist. Despite OFAC's initial denial, a license was later issued permitting the release of funds, which had escheated to the New York Office of the Comptroller. Askan amended its complaint to include the Comptroller, who agreed to return the funds with interest. OFAC moved to dismiss the case, asserting mootness, as the funds were returned and all requested relief provided. The court agreed, finding Askan's claims moot under the doctrines of mootness, voluntary cessation, and lack of standing for future relief. The court also addressed due process claims, concluding they were moot, as past actions had been resolved without ongoing implications. The court granted the government's motion to dismiss for lack of subject-matter jurisdiction, emphasizing that no effective judicial relief could be provided given the circumstances.

Legal Issues Addressed

Administrative Procedure Act (APA) Violations

Application: Askan's claim that OFAC delayed its license request processing was considered moot since the license had been issued and no ongoing harm could be addressed by the court.

Reasoning: Count Two alleges that OFAC's delay in processing Askan's license request violated the Administrative Procedure Act (APA), specifically 5 U.S.C. § 555(e) and 706(1).

Capable of Repetition, Yet Evading Review Exception

Application: The court found Askan's claims did not meet the standard for this exception, as there was no indication of ongoing or future harm that would evade review.

Reasoning: A challenge may not be moot if the alleged legal wrong is capable of repetition yet avoids review, referencing relevant case law.

Due Process under the Fifth Amendment

Application: Askan's due process claims regarding OFAC's actions were dismissed as moot because the alleged past violations had been resolved and did not impact current rights.

Reasoning: Counts Three and Four assert violations of due process under the Fifth Amendment, alleging that OFAC failed to identify the sanctioned individual responsible for blocking Askan's property.

Freedom of Information Act (FOIA) Violation Claims

Application: Askan claimed OFAC violated FOIA by not publishing a general license, but the court deemed these claims moot because all requested relief had already been provided.

Reasoning: In Count One of Askan's complaint, it is alleged that the Office of Foreign Assets Control (OFAC) violated the Freedom of Information Act (FOIA) by failing to publish the general license allowing the escheatment of blocked funds.

Mootness Doctrine

Application: The court found that Askan's claims were moot as the relief sought had already been provided, thus the court could not grant effective relief.

Reasoning: Federal courts lack jurisdiction over moot cases, which occur when intervening events prevent the court from granting effective relief.

Voluntary Cessation Doctrine

Application: The court rejected Askan's argument that OFAC's issuance of the license was voluntary cessation, as the specific conduct was unlikely to recur.

Reasoning: Askan invokes the voluntary cessation exception, contending that OFAC's actions create a reasonable expectation of recurrence of the violation.