OFAC Attorney: The existence of unlisted blocked entities makes doing international business even riskier. Proper due diligence requires more than just simply cross-checking potential business partners, for example, against OFAC’s SDN list. U.S. persons must now investigate the underlying ownership interest of each potential business partner to determine whether any of those interests are considered blocked. Only after a U.S. person has successfully peeled away the ownership interest layers of an entity will that U.S. person know if it’s authorized to proceed in a proposed business deal.
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