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Sanctions

Eliminating Terrorist Financing Without Damaging Legitimate Transactions

Addresses Terrorist Finance Elimination and Legitimate Transaction and Family Remittance Enhancement

Eliminating Terrorist Funding while Enhancing Legitimate Commercial Transactions and Family Remittances There is consensus that financing terrorism, via the international financial system, must be systematically eradicated while maintaining channels for legitimate commercial and family-related financial transactions.  Unfortunately, many international banking conglomerates refuse to do business with certain countries altogether, as their costs of compliance outweigh […]

New OFAC Secondary Sanctions Against Hizballah

Sanctions for Foreign Banks Business with Hezbollah

OFAC Issues Secondary Sanctions for Foreign Banks Doing Business with Hizballah On April 14, 2016, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new secondary sanctions (found in 31 C.F.R. 566 (pdf)) to implement the Hizballah International Financing Prevention Act of 2015. The new secondary sanctions target foreign financial institutions […]

A Closer Look at OFAC’s General License H

OFAc's General License H: A Closer Look

Back in July (2015) the permanent members of the UN Security Council (China, France, Russia, the United Kingdom, and the United States), Germany (collectively the P5+1), the European Union, and Iran reached a Joint Comprehensive Plan of Action (JCPOA) to ensure that Iran’s nuclear program would be exclusively peaceful.

North Korea’s Global Weapons Proliferation Network Targeted by OFAC Sanctions

North Korea's Weapons Proliferation Sanctioned

On December 8th, 2015, the Treasury Department’s Office of Foreign Assets Control (OFAC) took aim at the North Korean government’s attempts to procure weapons of mass destruction (WMDs) and related materials for production, presumably for the assembly of a strategic rocket force. Six North Korean nationals and three North Korean shipping companies have been added […]

OFAC Sanctions Prominent Japanese Yakuza Member

Former Yakuza Member Tadamasa Goto Sanctioned

On December 9th 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a press release designating Tadamasa Goto, a Japanese yakuza or gangster member known as the John-Gotti of Japan, as person completely prohibited from dealing with U.S. financial markets.

OFAC Sanctions Three Members of a Powerful Honduran Family and their Bank

Powerful Honduran and Their Bank Sanctioned

On October 7, 2015 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it had made several major designations pursuant to the Foreign Narcotics Kingpin Designation Act (Kingpin Act).  OFAC designations (opens as pdf) were made against Jaime Rolando Rosenthal Oliva, along with his son, Yani Benjamin Rosenthal Hidalgo, and […]

Navigators Insurance and The Importance of An OFAC Compliance Program

OFAC Compliance & Navigators Insurance

OFAC Fines Navigators Insurance Company without Compliance Program for Apparent Violations of Various Sanctions Programs. Several interesting things stand out regarding OFAC’s enforcement action against Navigators Insurance Company (“Navigators”).  On August 6, 2015, OFAC entered into a settlement agreement with Navigators to settle potential liability for apparent violations of the North Korea, Iran, Sudan, and […]

Vienna Agreement With Iran: New Opportunities For U.S. Companies?

Agreement With Iran & New Opportunities For U.S. Companies

The Agreement concluded by the six world powers and the Islamic Republic of Iran in regard to its nuclear program, represents an historic moment in the diplomatic relations between the United States and Iran and, simultaneously, opens to the American business-world the possibility of new and previously unimaginable opportunities. Though the Joint Comprehensive Plan of […]

The U.S. Secondary Sanctions System

Secondary Sanctions Program in the U.S.

Impact on European Banks and Companies The American sanctions system against the Islamic Republic of Iran found its origins some years after the outbreak of the Iranian Revolution of 1979, becoming more restrictive in 1995 when President Clinton (see right) prohibited U.S. persons and entities from engaging in most transactions with Iran.[1] These restrictions concerned […]

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