-2-Assets Control (OFAC), Salah is prohibited from purchasing virtually anything, including food,clothing, and lodging, and it is a crime for any United States citizen, permanent resident, entityorganized under U.S. law, or any other person in the United States or its territories to engage invirtually any transaction with Salah, including providing him with food, shelter, clothing, or many medical services
even if they are provided free of charge. Salah may not work for aliving, spend money, or give or accept any donations absent advance approval by OFAC. Therestrictions are so onerous that they are practically impossible to comply with.3.
OFAC has at various times granted Salah licenses that in theory authorize him todo limited things, such as get a job, open a bank account, and pay for and receive “goods andservices essential to [his] basic maintenance.” But they have come with onerous obligations, andOFAC has unfettered discretion to grant or deny such licenses, subject to whatever conditions itchooses. Salah survives, in other words, only at the sufferance of OFAC. Moreover, becauseOFAC has authorized only basic maintenance, he is prohibited from engaging in transactionsnecessary to do anything that might not be deemed “basic maintenance,” and thus is left to guessat whether spending money for any of the following activities are permissible: attending alecture, concert, or movie with his wife; taking his children to a sporting event; buying hischildren birthday presents; contributing to a political campaign; purchasing a book or newspaper;or satisfying his religious charitable obligations by donating to his local mosque or other charitable entities. As a result of his designation and the onerous reporting requirements OFAChas attached to licensing a bank account, Salah has been unable, with one short-lived exception,to identify a bank that will accept an account on his behalf. It has also been all but impossiblefor him to find employment. Salah has lived under these unprecedented conditions for more thanseventeen years, with no end in sight. No other U.S. citizen must seek such specific advance
Case: 1:12-cv-07067 Document #: 1 Filed: 09/05/12 Page 2 of 16 PageID #:2