“OFAC Issues New Guidance Regarding Entities Owned by one or More Designated Parties”

August 19, 2014

The National Law Review on August 18, 2014 released the following:

“On August 13, 2014, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new guidance advising that it has changed its policy governing whether entities that are owned by individuals or entities designated under Executive Orders and regulations administered by OFAC, but are not themselves designated, are also subject to U.S. sanctions.

Pursuant to this new guidance, any entity that is owned 50 percent or more in the aggregate, directly or indirectly, by one or more parties on OFAC’s Specially Designated Nationals and Blocked Persons List (“SDN List”) is subject to blocking.1 This is a significant departure from prior OFAC guidance that it was not necessary to aggregate the ownership interests of separate SDN-Listed parties to determine whether a non-listed entity was considered to be blocked.

The new “50 Percent Rule” provides that, effective immediately, the property and interests in property of any entity owned 50 percent or more in the aggregate, directly or indirectly, by persons designated on the SDN List that are, or come into, the United States or the possession of control of a U.S. person are blocked and cannot be dealt in absent licensing or other authorization from OFAC. This means that U.S. persons are effectively prohibited from engaging in any dealings with any entity directly or indirectly owned 50 percent or more in the aggregate by one or more blocked parties regardless of whether such entity is itself designated on the SDN List.

In Frequently Asked Questions (“FAQs”) that OFAC issued on August 14 clarifying the scope of the new 50 Percent Rule, OFAC has provided that this new aggregation test also applies in determining whether entities that are not on the Russian Sectoral Sanctions Identifications (“SSI”) List are subject to the sanctions that apply to the SSI-Listed Russian banks and oil companies. Entities on the SSI List, and entities owned 50 percent or more in the aggregate by such SSI-Listed entities, are not subject to comprehensive blocking measures. Rather, they are subject to a more limited set of restrictions related to new debt with a maturity of longer than 90 days and, in the case of the SSI- Listed banks, new equity, in either case issued by, on behalf of, or for such an entity. For more information on the full scope of SSI List restrictions, please see our prior E-Alert dated July 30, 2014.

THE SCOPE OF THE 50 PERCENT RULE

OFAC’s FAQs offer the following additional guidance concerning the application of the new 50Percent Rule:

1 Certain OFAC sanctions programs are broader and also target entities that are controlled by sanctioned parties. For example, the Iranian Transactions and Sanctions Regulations apply to entities that are owned or controlled by the government of Iran. See 31 C.F.R. §§ 560.304 and 560.313. The 50 Percent Rule’s focus on ownership does not limit the broader scope of these sanctions programs.

The 50 Percent Rule applies only to ownership interests, not control. According to OFAC, “[a]n entity that is controlled (but not owned 50 percent or more) by one or more blocked persons is not considered automatically blocked” pursuant to the 50 Percent Rule. Nonetheless, companies should proceed with caution when considering a transaction with an entity that one or more blocked parties may control because OFAC could add that entity to the SDN List at some point in the future.

Consistent with prior guidance that OFAC has issued, companies should be careful not to negotiate, enter into contracts, or process transactions that involve a blocked person when the blocked person is acting on behalf of a non-blocked entity. OFAC sanctions “prohibit transactions involving, directly or indirectly, a blocked person…even if the blocked person is acting on behalf of a non-blocked entity.” This includes, for example, situations in which a blocked person signs a contract on behalf of a non-blocked entity.

Indirect ownership refers to “ownership of shares of an entity through another entity or entities that are 50 percent or more owned in the aggregate by the blocked person(s).” This means that if Blocked Person X owns 50 percent of Entity A, and Entity A owns 50 percent of Entity B, then both Entity A and B are blocked — Entity A because it is directly owned 50 percent by Blocked Person X and Entity B because it is owned 50 percent by blocked Entity A. Similarly, if Blocked Person X owns 50 percent of Entity A and 10 percent of Entity B, and Entity A also owns 40 percent of Entity B, then Entity B is considered as blocked based on the aggregate 50 percent ownership of Entity B by two blocked parties.

By contrast, indirect ownership does not apply at all where a blocked party owns less than a 50 percent interest in the intermediate entity. Thus, if Blocked Person X owns only 25 percent of Entity A and 25 percent of Entity B, no matter how large an interest Entities A and B hold in Entity C, Entity C will not be considered blocked. This is because Blocked Person X’s 25 percent ownership of each of Entity A and Entity B falls short of 50 percent. Accordingly, neither Entity A nor Entity B is blocked and, for purposes of the 50 Percent Rule, Blocked Person X is not considered to indirectly own any of Entity C as a result of its minority ownership of Entities A or B.

While all of the OFAC examples in the FAQs address circumstances involving a single Blocked Person, the guidance would apply more broadly. For example, if Blocked Person X owns 50 percent of Entity A, and Entity A owns 25 percent of Entity B, and Blocked Person Y owns 50 percent of Entity C, which also owns 25 percent of Entity B, then the combination of the indirect ownership and 50 Percent Rule requirements may make Entity B a blocked person. While the FAQs do not address this situation, we believe OFAC would consider Entity B to be a blocked person since Entities A and C would each be considered blocked entities because of their 50 percent ownership by blocked persons, and in the aggregate they own 50 percent of Entity B.

Companies likely will need to undertake significant additional due diligence in order to collect the information about direct and indirect ownership interests that is necessary to make these complex calculations and to aggregate ownership information across multiple levels of a corporate structure. Indeed, OFAC urges companies considering a transaction to conduct “appropriate due diligence” on the involved entities in order to determine relevant ownership stakes.

Under certain limited circumstances, it may be possible for one or more blocked persons to divest their ownership stake in an entity in order to ensure that the combined ownership by blocked persons in the entity is less than 50 percent. However, these actions must be undertaken entirely outside of U.S. jurisdiction and without the involvement of any U.S. persons. Companies also should be careful to avoid “sham transactions” by conducting sufficient due diligence to be confident that any purported divestment actually occurred before they enter into any dealings with entities that were previously owned 50 percent or more by one or more designated parties.

If the aggregate ownership of blocked parties in an entity falls below 50 percent due to the actions of one or more of the blocked parties, including the entity itself, any property or interests in property that were previously in the United States or the possession or control of a U.S. person remain blocked and cannot be dealt in absent licensing or other authorization from OFAC. This is because OFAC does not recognize the unlicensed transfer of blocked property in the United States or in the possession or control of a U.S. person. This position imposes an additional layer of due diligence as it suggests that U.S. persons may need to conduct a retrospective analysis of the property of entities that they learn are minority owned by a blocked party in order to ensure that the entity was not previously owned 50 percent or more in the aggregate by blocked parties.”

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Douglas McNabb – McNabb Associates, P.C.’s
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To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition Defense, OFAC SDN Sanctions Removal, International Criminal Court Defense, and US Seizure of Non-Resident, Foreign-Owned Assets. Because we have experience dealing with INTERPOL, our firm understands the inter-relationship that INTERPOL’s “Red Notice” brings to this equation.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.

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“U.S. Imposes Sanctions on Those Aiding Iran”

May 10, 2013

The New York Times on May 9, 2013 released the following:

By RICK GLADSTONE

“The United States on Thursday expanded its roster of those violating Iran sanctions, blacklisting four Iranian companies and one individual suspected of helping the country enrich nuclear fuel. It also singled out two other companies, including a Venezuelan-Iranian bank, accused of helping Iran evade other Western-imposed prohibitions on oil sales and financial dealings.

The penalties announced by the Treasury and State Departments came a day after the Senate introduced legislation that could effectively deny the Iran government access to an estimated $100 billion worth of its own money parked in overseas banks, a step that proponents said could significantly damage Iran’s financial stability.

That legislation, known as the Iran Sanctions Loophole Elimination Act, is expected to be integrated into a broader House measure introduced in February.

The actions on Thursday appeared to signal an accelerated American effort to squeeze Iran economically over the lack of progress in negotiations on the disputed Iranian nuclear program, which Iran says is peaceful but the West has called a guise to achieve the ability to make atomic bombs.

The latest round of negotiations last month ended inconclusively, and Western critics of Iran have accused it of stalling for time while it continues to enrich uranium.

“With Iran’s nuclear program marching steadily forward, we need to work as quickly as possible to eliminate any sources of funding for the regime,” the chairman of the House Foreign Affairs Committee, Representative Ed Royce, a California Republican, said in a statement issued jointly with the ranking Democrat, Representative Eliot Engel of New York.

They said the committee would hold a hearing Wednesday on Iran’s nuclear activities.

Any assets that blacklisted companies or individuals may have under American jurisdiction can be frozen, and they are prohibited from doing business with American citizens or businesses. Other individuals or business that engage with those under sanctions are themselves subject to penalties.

Iran has characterized the sanctions as illegal bullying by the United States and its allies. Some critics of the sanctions have said they are more likely to harden Iran’s resistance.

A State Department announcement said four Tehran-based businesses, identified as Aluminat, Pars Amayesh Sanaat Kish, Pishro Systems Research Company and Taghtiran Kashan Company, and an Iranian citizen from Tehran identified as Parviz Khaki, were all blacklisted for providing goods, technology and services for activities that violated United Nations Security Council sanctions on Iran’s nuclear activities.

“This action was taken in light of the ongoing concerns that the international community has with respect to Iran’s nuclear program, which Iran continues to refuse to address,” the State Department announcement said.

In what appeared to be a coordinated announcement, the Treasury Department’s Office of Foreign Assets Control, which helps administer sanctions, announced that it was punishing Sambouk Shipping FZC, based in the United Arab Emirates, for cloaking the origin of Iranian oil and selling it on the international market. The Treasury said that the company was owned by a Greek business executive, Dmitris Cambis, who was blacklisted earlier this year for ties to sanctioned Iranian companies.

In addition, the Treasury penalized the Iranian Venezuelan Bi-National Bank, based in Tehran, for engaging in financial transactions for the Export Development Bank of Iran, which has already been blacklisted.

“As Iran becomes increasingly isolated from the international financial system and energy markets, it is turning increasingly to convoluted schemes and shady actors to maintain its access to the global financial system,” David S. Cohen, the under secretary for terrorism and financial intelligence, said in the Treasury announcement. “As long as Iran tries to evade our sanctions, we will continue to expose their deceptive maneuvers.””

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Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

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To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition Defense, OFAC SDN Sanctions Removal, International Criminal Court Defense, and US Seizure of Non-Resident, Foreign-Owned Assets. Because we have experience dealing with INTERPOL, our firm understands the inter-relationship that INTERPOL’s “Red Notice” brings to this equation.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.

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“OFAC Removes Colombians, Iranian from Blacklist”

April 30, 2013

The Wall Street Journal on April 30, 2013 released the following:

“The U.S. Treasury Department’s Office of Foreign Assets Control said Tuesday it removed 16 Colombians, a Colombian company and an Iranian from its blacklists.

By Samuel Rubenfeld

The U.S. Treasury Department’s Office of Foreign Assets Control said Tuesday it removed 16 Colombians, a Colombian company and an Iranian from its blacklists.

A Treasury spokesman said in an email the individuals petitioned OFAC to remove their names, and they provided the office with sufficient information to prove they cut their ties with those that led them to be placed under Kingpin Act sanctions in the first place.

“The decision by OFAC…is evidence of the fair process of administrative review, and shows that inclusion on the SDN List is not always permanent,” the spokesman said.

In addition, OFAC removed Hessam Khoshnevis from its Iran and counter-terrorism sanctions lists. Khoshnevis, a commander in Iran’s Revolutionary Guard, was reportedly killed in Syria by rebels fighting the Bashar al-Assad regime.”

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Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition Defense, OFAC SDN Sanctions Removal, International Criminal Court Defense, and US Seizure of Non-Resident, Foreign-Owned Assets. Because we have experience dealing with INTERPOL, our firm understands the inter-relationship that INTERPOL’s “Red Notice” brings to this equation.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.

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International criminal defense questions, but want to be anonymous?

Free Skype Tel: +1.202.470.3427, OR

Free Skype call:

           Office Locations

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US Sees ‘Worrying Trend’ in Venezuela Drug Trafficking

April 18, 2012

In Sight on April 17, 2012 released the following:

“Written by Christopher Looft

A US Treasury official said that the department had observed a “worrying trend” in drug trafficking in Venezuela in the last two years, and that Henry Silva Rangel, now the country’s defense minister, had called for closer government cooperation with the FARC rebel group.

Adam Szubin [], director of the Treasury Department’s Office of Foreign Assets Control (OFAC), told El Universal that Defense Minister Henry Rangel Silva, who the department designed as a narcotics traffickers in 2008, “has argued for better cooperation between the Venezuelan government and the FARC.”

Rangel Silva was accused by OFAC of “materially assisting the narcotics trafficking activities” of the Colombian rebel group. A top intelligence official at the time, he was sanctioned along with another intelligence official and the former interior minister for ties to the group. Another four government officials were designated in 2011.

The Foreign Narcotics Kingpin Designation Act targets individuals and businesses with suspected ties to international drug trafficking by freezing their US assets and barring US individuals and businesses from commercial ties with them.

Szubin assured the newspaper that “nobody enters OFAC’s list by mistake.”

InSight Crime Analysis
There have long been accusations of ties between the FARC and elements of the Venezeulan government and military. High-ranking members of the rebels’ ruling Secretariat are thought to use the country as a refuge, as well as a source of weapons and medical care.

These accusations were bolstered earlier this year when President Hugo Chavez appointed Rangel, then a high ranking general, as defense minister, despite the accusations that he has helped the FARC to smuggle drugs. His appointment was likely part of efforts by an ailing Chavez to shore up political power. The ties between the two are strong; as military officers, they collaborated in a 1992 coup attempt.

However, since a rapprochement with the Colombian government in 2012, Venezuela has been working more closely with its neighbor to catch and deport members of the rebel group. In March 2012, Venezuelan authorities cooperated with Colombia to capture one of the group’s founding members.”

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Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN Sanctions Removal.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.


U.S. eases financial sanctions on Myanmar

April 18, 2012

english.vietnamnet.vn on April 18, 2012 released the following:

“The U.S. Treasury Department announced on Tuesday that it will ease the financial sanctions on Myanmar in order to allow the American non-governmental organizations (NGOs) to operate in the country.

The U.S. government will drop financial sanctions on Americans whose activities are aimed at meeting basic human needs and promoting democracy in the Southeast Asian country, according to Treasury Department’s Office of Foreign Assets Control.

To be specific, the activities exempted from sanctions, which are typically carried out by the NGOs, include health, education, good governance and certain non-commercial development initiatives, said the department.

“These were our action for action, if you will, in response to what we viewed as very positive parliamentary elections,” State Department spokesman Mark Toner said in his comment on the announcement.

“I think you’ll see more steps as we implement what we laid out on April 4. You’ll see additional steps,” he told reporters.

On April 4, U.S. Secretary of State Hillary Clinton announced that Washington will ease its financial and investment restrictions on Myanmar, following the landmark parliamentary by- election in the country.

She also said that the United States was expected to nominate an ambassador to Myanmar very soon, to establish an in-country USAID mission and to support a normal country program for the UN Development Program.

Tuesday’s decision by the Treasury Department signaled Washington’s first step to loosen its wide-ranging and longtime sanctions on Myanmar.

Myanmar held its historic parliamentary by-election on April 1, in which the opposition party led by Aung San Suu Kyi secured big gains, winning 43 of 45 parliamentary seats available.

VietNamNet/Xinhuanet”

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Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN Sanctions Removal.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.


OFAC Details Permissible Information Technology Exports To Iran

March 21, 2012

The Wall Street Journal on March 20, 2012 released the following:

“By C.M. Matthews

The U.S. Treasury Department issued guidance and licensing information Tuesday on Internet, social media, software and other information products that can be exported to Iran.

Following the disputed Iranian presidential election in 2009, U.S. officials took note of the importance social media and other technologies played in organizing opposition protests to the regime of President Mahmoud Ahmadinejad. In March 2010, the Treasury Department’s Office of Foreign Assets Control authorized U.S. exports to Iran of certain services and software related Internet communications.

Tuesday’s guidance clarifies what technologies can be sent to Iran. The permitted exports are broken into eight categories:

  • Personal Communications (e.g., Yahoo Messenger, Google Talk, Microsoft Live, Skype (non-fee based))
  • Updates to Personal Communications Software
  • Personal Data Storage (e.g., Dropbox)
  • Browsers/Updates (e.g., Google Chrome, Firefox, Internet Explorer)
  • Plug-ins (e.g., Flashplayer, Shockwave, Java)
  • Document Readers (e.g., Acrobat Readers)
  • Free Mobile Apps Related to Personal Communications
  • RSS Feed Readers and Aggregators (e.g., Google Feed Burner)

OFAC also said it is clarifying its existing licensing policy to make it more “favorable” for U.S. persons seeking approval to export items “that directly benefit the Iranian people” not covered by current regulations.

“It is essential that people have the freedom to seek, receive and impart information through a variety of mediums, including the Internet,” the Treasury Department said in a news release. “By jamming satellites and censoring the Internet, the Iranian regime has erected an electronic curtain that prevents the Iranian people from communicating with the outside world and with each other.””

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Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN Sanctions Removal.

The author of this blog is Douglas C. McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.


Obama Signs Executive Order Putting Tougher Sanctions on Iran

February 7, 2012

The Cypress Times on February 6, 2012 released the following:

“WASHINGTON, DC – Today, President Obama signed an Executive Order (E.O.) that takes a number of actions in furtherance of the Administration’s Iran sanctions program, including measures to implement section 1245 of the National Defense Authorization Act (NDAA). Among other things, the E.O. freezes all property of the Central Bank of Iran and all other Iranian financial institutions, as well as all property of the Government of Iran, further tightening the already broad-based and stringent U.S. sanctions on Iran.

These actions underscore the Administration’s resolve to hold the Iranian regime accountable for its failure to meet its international obligations. Iran now faces an unprecedented level of pressure due to intensified sanctions applied by the United States and complementary actions by many others around the world. The new E.O. issued today reemphasizes this Administration’s message to the Government of Iran – it will face ever-increasing economic and diplomatic pressure until it addresses the international community’s well-founded and well-documented concerns regarding the nature of its nuclear program.

Additional information describing the implementation of section 1245 of the NDAA pursuant to the authorities delegated under this E.O. will be made available in the near term.

Sanctions under the New Executive Order:

On February 5, President Obama signed a new E.O. effective at 12:01 a.m. on February 6, that blocks (i.e., “freezes”) all property of the Government of Iran as well as all property of Iranian financial institutions, including the Central Bank of Iran.

1. The E.O. blocks all property and interests in property of the Government of Iran, the Central Bank of Iran and all Iranian financial institutions (regardless of whether the financial institution is part of the Government of Iran) that are in the United States, that come within the United States, or that come within the possession or control of U.S. persons. Previously, U.S. persons were required to “reject,” rather than “block,” Iranian transactions.

  • Under the order, the Government of Iran, the Central Bank of Iran, and all Iranian financial institutions are now blocked (i.e. their assets within the jurisdiction of U.S. persons are frozen).
  • The U.S. sanctions in place since 1995 have required most transactions involving the Government of Iran, the Central Bank of Iran and all Iranian financial institutions to be rejected – that is, they could not pass through the U.S. financial system, but instead were turned back. Under the new E.O., transactions involving the Government of Iran, the Central Bank of Iran and all Iranian financial institutions that previously would have been rejected will now be blocked.
  • All entities that meet the existing definition of “Government of Iran,” such as Iranian ministries, state-owned entities and commercial firms owned or controlled by the Government of Iran, are blocked. This includes entities bearing the [IRAN] tag on the Treasury Department’s Office of Foreign Assets Control’s (OFAC) List of Specially Designated Nationals and Blocked Persons (SDN List). Transactions by U.S. persons involving such entities are now blocked unless exempt or otherwise authorized. OFAC will continue to update the SDN List and may add, delete, or edit existing entries as appropriate.
  • The E.O. does not change the sanctions that may be applied against foreign financial institutions engaging in arms-length transactions with certain Iranian financial institutions, including the Central Bank of Iran. Those foreign financial institutions remain at risk of U.S. sanctions if they engage in certain significant financial transactions with the Central Bank of Iran or certain other designated Iranian financial institutions pursuant to the NDAA, or the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA).

2. Treasury is issuing general licenses to maintain existing authorizations for certain transactions that advance U.S. foreign policy interests.

  • Persons who currently use general or specific licenses from OFAC for transactions involving the Government of Iran or Iranian financial institutions should consult the OFAC website for new general licenses and other information on whether those transactions remain authorized under the new E.O.

Delegations of Authority under the New Executive Order:

The E.O. also delegates other authorities provided in section 1245(d) of the NDAA.

  • The E.O. delegates a number of other authorities provided in section 1245(d) of the NDAA, primarily to the Departments of the Treasury and State. These delegations will facilitate the implementation of section 1245 of the NDAA.
  • Additional information describing the implementation of the NDAA under these delegated authorities will be made available in the near term.”

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Douglas McNabb – McNabb Associates, P.C.’s
OFAC SDN Removal Videos:

OFAC Litigation – SDN List Removal

OFAC SDN List Removal

OFAC SDN Removal Attorneys

————————————————————–

To find additional global criminal news, please read The Global Criminal Defense Daily.

Douglas McNabb and other members of the U.S. law firm practice and write and/or report extensively on matters involving Federal Criminal Defense, INTERPOL Red Notice Removal, International Extradition and OFAC SDN Sanctions Removal.

The author of this blog is Douglas McNabb. Please feel free to contact him directly at mcnabb@mcnabbassociates.com or at one of the offices listed above.