Menu Home

Did you read OFAC FAQ 936?

It says that Hidri Trust and Red Sea Trading Corporation are not subject to the 50 Percent Rule. How does that happen? Section 2(b) of Executive Order includes the following: No entity shall be blocked pursuant to this order solely because it is owned in whole or in part, directly […]

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 […]