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OFAC

If we take out the hyperbole inherent in American notices (e.g. "violation" instead of "breach" and the profligate use of words like "egregious") we get to a nitty gritty that is a stone in the shoe, a thorn in the side or any one of a dozen bon mots that indicate how and why compliance officers need to be abreast of principles more than data. One has to feel some sympathy with State Street. The case also have implications for citizens of one country living abroad, especially pensioners.

Publication: 

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.

Publication: 

The US Department of the Treasury will shortly modify the website at www.treasury.gov. The change will affect, inter alia, users of the OFAC sanctions lists. A notice, reproduced below, verbatim, informs users about the changes.
BIScom Subsection: 

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.

Publication: 

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: 

A correspondent asks "As a UK individual how do I report / alert the US authorities to the a craptocurrency used by employees and the Chairman of a group of companies with offices in St Louis, Missouri ?"

Here's the answer, and it explains differences between OFAC and FinCEN, etc. reports.

BIScom Subsection: 

On 19th March, the USA's Office of Foreign Assets Control, a division of the US Treasury, which publishes lists of persons sanctioned under trade and economic policies, under policies that are political including but not limited to national security plus those under the USA PATRIOT Act announced that it was to include, where it has it, cryptocurrency data relating to subjects. Just what are they planning and what will it mean for crypto-currency holders and exchanges and businesses such as online auctions and advertising platforms?

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."