|R Richard Newcomb, Esq.|
Counsel for Reza Zarrab has notified the Court, in a filing, that former OFAC Director R Richard Newcomb will serve as an expert witness on behalf of their client. Newcomb, who was Director of the Office of Foreign Assets Control, for 18 years, is presently a partner at a major law firm.
In their Summary of the Witness' Opinion, defense counsel stated that Newcomb will testify that the IEEPA has jurisdictional limits, that it does not apply to conduct by non-US individuals, that occurs entirely outside the United States, and that it is the longstanding policy of OFAC not to target non-US individuals, acting entirely outside the United States. He is basically taking the position that Zarrab is a person not subject to the jurisdiction of the United States, therefore not subject to OFAC restrictions.
There is a motion to dismiss pending in this action, but its September 6 hearing date was cancelled, due to the pending defense motion to recuse the District Judge, Richard M Berman.