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Any business that does business in or via the USA, including doing business in US Dollars is subject to US sanctions law. The USA frequently punishes foreign businesses which it says has breached its sanctions law. While the media focus is usually on action against UK and EU banks, the simple fact is that successful actions have been brought against, even, individuals buying and selling goods via eBay. So, when the US Treasury says "this is how to design your compliance system," it makes a great deal of sense to pay attention. Yesterday, that's what it said. So pay attention.


On 2 July, 2018, OFAC issued a recent action notice [ https://www.treasury.gov/resou... ] notifying persons holding property blocked pursuant to OFAC sanctions regulations published in Chapter V of Title 31 of the Code of Federal Regulations of the requirement, as outlined in 31 C.F.R. 501.603, to provide OFAC with a comprehensive report on all blocked property held as of June 30 of the current year by 30 September.


Early on Saturday morning,in Setapek, one of Kuala Lumpur's most racially and religiously integrated suburbs, two men in dark, full face, helmets sat on a rare, high-powered, motorcycle for some twenty minutes. As Palestinian FADI Mohammad al Batsh, 35, passed by on his way from his home to lead dawn prayers in his role as imam, the man on the back of the bike shot him. Police reports say that he was shot four times with a high degree of accuracy: there were only two stray bullets found out of evidence that ten shots were fired. Two men nearby were not harmed. This was not a simple murder, the circumstances suggest.

CoNet Section: 

Chinese telecommunications giant ZTE and its subsidiaries and associates were investigated for "apparent" breaches of US sanctions, in particular a trade embargo with Iran.

Zhongxing Telecommunications Equipment Corporation is incorporated in China and has subsidiaries and "affiliates throughout the world that conduct business on ZTE and on its behalf," according to OFAC.

A civil penalty has been applied. No prosecution will take place. There is a finding of no fault despite what OFAC calls "an egregious case."