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What gives a sanctions person nightmares?

The OFAC 50 Percent Rule, and whether or not it applies to the Chinese Military Companies program, of course. It’s a short way of saying, I have a new episode of Mr. Watchlist’s DesigNation – Mr. Watchlist’s Nightmare. Now, I’m experimenting here… hopefully, a little web player just appeared… if […]

The fun starts on page 14…

of the Standard Chartered settlement with OFAC – it’s a roadmap to what real remediation looks like, and the standards for a firm of size and commercial sophistication are: Specifically, OFAC and Respondent understand that the following compliance commitments have been made: a. Management Commitment: i. Respondent commits that Senior […]

So, when does 44.95+10.55+24=0?

Ken Vogel at the New York Times reports about the “deal” struck between Oleg Deripaska and his firm EN+ Group, and the US Treasury Department (i.e. OFAC). Basically, as you may have read, under the deal, Deripaska reduced his ownership of EN+ Group, which controls the other 2 firms which […]

OFAC Enforcement Action: Cobham Holdings

Cobham Holdings settled 3 non-egregious, voluntarily self-reported violations of the Ukraine Related Sanctions Regulations for $87,507. In this case, the violations involved business dealings with a party majority owned by a sanctioned entity. Here are some interesting bits describing what happened: At all relevant times, although AAT was not explicitly […]

May Day, May Day: OFAC Tweaks Russia/Ukraine General Licenses

Issuance of Ukraine-/Russia-related General Licenses; Publication of New FAQs and Updated FAQs 5/1/2018   Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Ukraine-/Russia-related General License 12B, which replaces and supersedes General License 12A in its entirety.  General License 12B permits originating and intermediary U.S. financial institutions to […]

A chink in the EU’s 50% Rule…

Someone brought the following wording in EU decisions (such as EC 833/2014) about the 50% Rule to Mr. Watchlist’s attention:   any legal person, entity or body established outside the Union owned for more than 50 % by an entity listed in the Annex;  So, while this limits the impact […]