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OFAC Insurance Industry Regulations Compliance Lawyer

The OFAC regulations are not intended to penalize or cripple U.S. companies engaging in international business. Therefore, in some cases, an OFAC license may be granted for a specific license. In such a case, the insurer would also be required to obtain a separate license in order to pay claims arising under the global insurance policy.

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Agreement With Iran: New Opportunities For U.S. Companies

Vienna Agreement With Iran: New Opportunities For U.S. Companies? July 17, 2015. The Agreement concluded by the six world powers and the Islamic Republic of Iran in regard to its nuclear program, represents an historic moment in the diplomatic relations between the United States and Iran and, simultaneously, opens to the American business-world

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Doing Business with Customers on the SDN List …

Companies could ensure that they are complying with the SDN list as it is updated by having a compliance officer on staff and a subscription to the OFAC notification system. They would get notification as it is updated, which would allow the companies to be ready and make these changes that might help them stay compliant with the OFAC regulation.

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What OFAC's Crimea-related Prohibitions Mean

This means that companies like Visa and MasterCard can no longer provide payment services to merchants in Crimea. It also means that U.S. citizens or permanent residents residing in Crimea are no longer permitted to be employed in Crimea (i.e., exporting their U.S.-origin services to their Crimean employers).

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Money Service Business OFAC Compliance Lawyer

Obviously importers, exporters, shipping companies, and banks must be aware of all OFAC regulations and sanctions programs. However, all United States citizens and companies that have international dealings are also required to be in compliance with all OFAC regulations. This includes Money Service Businesses (MSB) that are involved in non-bank

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The U.S. Secondary Sanctions Program

July 9, 2015. Impact on European Banks and Companies. The American sanctions system against the Islamic Republic of Iran found its origins some years after the outbreak of the Iranian Revolution of 1979, becoming more restrictive in 1995 when President Clinton (see right) prohibited U.S. persons and entities from engaging in most transactions with Iran.

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ZTE and Huawei Sanctions Violation of U.S. Sanctions on Iran

Because these companies rely extensively on American goods to produce their products, these sanctions have had a serious impact and major implications for US-China relations. History of ZTE Sanctions ZTE Corporation is a Chinese multinational corporation engaged in the manufacturing and sale of telecommunication equipment.

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How to Protect Your Business from OFAC Sanctions

OFAC Attorney: One common practice of companies is to develop a sanctions compliance program. It is an instruction manual for the company, its officers, and its employees to help avoid sanctions violations and to educate their employees on what sanctions are, as well as what they need to look out for.

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OFAC Targets Russian Banks and Defense

OFAC Targets Russian Banks, Defense Technology. August 4, 2014. Aug. 4, 2014. On July 29, 2014, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the imposition of sectoral sanctions against additional entities operating within the financial services sector of the Russian economy.

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Who must comply with OFAC

OFAC Attorney: All U.S. persons are required to comply with OFAC regulations. U.S. persons are defined as any individual present in the United States and every U.S. citizen and U.S. permanent resident located anywhere in the world. The definition of U.S. persons also includes entities formed in the United States or incorporated in the United

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50 Percent Rule FAQ OFAC Lawyer

OFAC Attorney: The 50 percent rule is how OFAC determines whether companies not appearing on the SDN list are considered blocked because they are owned by other companies or people who do appear on the SDN list.. Persons whose property and interest in property are blocked pursuant to an executive order or regulations that are administered by OFAC are considered …

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BSA-Regulated "Financial Institutions" FinCEN Compliance

A “financial institution” subject to regulation under the BSA is a term of art that covers a much wider array of businesses and institutions than what one would normally think of as a financial institution. See 31 CFR Section 5312(a)(2). The definition includes: An insured bank; A commercial bank or trust company; A private banker; An agency or branch of a foreign bank …

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OFAC Functions OFAC Law Group

This list provides the names of individuals, companies, groups, and other entities that pose a threat to U.S. national security, foreign policy, and economic goals. Whether working alone, as part of a terrorist or criminal network, or on behalf of a targeted country or regime, those noted as SDNs are the specific targets of sanctions and

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Iran Sanction Laws Iranian Transaction Sanctions Regulations

US companies who have foreign subsidiaries relying on General License H to conduct business in Iran need to change their General License H policies to ensure that only wind-down activities occur from now until November 6, 2018. While accepting new customers is prohibited, it will be important for compliance personnel to consult with foreign

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OFAC Sectoral Sanctions Russia Ukraine and Venezuela

OFAC sectoral sanctions are a new category of sanctions. The US has had secondary sanctions, list-based sanctions, and country-based sanctions, but this is the new category that OFAC introduced and began using in the Ukraine-related Sanctions and arguably in a more targeted fashion the Venezuela-related Sanctions. For more information on the recent changes, contact …

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General License H: OFAC Authorizations & US Subsidiaries

In the pre-Implementation Day sanctions environment—and even now—the difficulties involved in finding vetted agents and partners posed serious problems for US persons engaged in authorized business and activities with Iran. It has historically been a major risk that companies needed to account for in any cost-benefit calculus.

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OFAC SDN List Removal Lawyer: FAQs

Many foreign companies also employ U.S. persons and do business with U.S. companies, which create complicated compliance issues if they were to also do business with people whose names appear on the SDN List. It’s often easier and less risky to simply refuse to do business with designated persons.

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OFAC Requirements for Importers and Exporters

OFAC Requirements for Importers and Exporters. Each industry has specific requirements for complying with economic transactions and trade sanctions in accordance with the sanctions programs administered by the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC violations may lead to blocked property

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Charitable Donations and OFAC Sanctions Personal

Charitable Donations and OFAC Sanctions. Under the Office of Foreign Assets Control (OFAC) sanctions, individuals and companies may be prohibited from doing business with a certain foreign government, company, or national. However, OFAC sanctions can also play a role in charitable giving to nonprofit organizations.

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OFAC Economic Sanctions Programs Secondary Sanctions

OFAC Economic Sanctions Programs. The United States, through the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC), employs economic sanctions programs for a variety of purposes, including: National Security. Initially, economic sanctions were adopted pursuant to the 1917 Trading with the Enemy Act (TWEA).

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End of Ivory Coast Sanctions

It targeted specific individuals and required companies in the United States to screen all parties involved in transactions to make sure that none of the names of the parties involved, including intermediaries and third party service providers, were on the SDN list or were owned or controlled by parties on the SDN list.

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OFAC Attorney Explains the SDN List OFAC Sanctions Attorney

I’ve seen people lose their jobs in major multinational companies, lose their pensions, and lose access to other important property as a result of being placed on the SDN list. If there is a case of mistaken identity, there is an administrative process within OFAC to remedy the situation.

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Cash Purchases Complicate Real Estate Buys For Immigrants

The GTOs will require title insurance companies to conduct enhanced due diligence, know their customers, and to file a report with FinCEN when necessary. This is a laudable effort by FinCEN to close a recognized gap in the financial system’s broader anti-money laundering framework.

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Rusal Sanctions Lifted Barker Plan Reduces Deripaska's

Rusal, En+, and other previously Deripaska-owned companies can now continue to engage in business as usual. Significance of the Rusal Sanctions and Barker Plan. The designation of Oleg Deripaska’s companies and subsequent sanctions relief shows that OFAC can have a powerful impact on world markets.

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OFAC Targeted Countries and Regimes

OFAC-administered sanctions are imposed against targeted countries and regimes, as well as individuals and companies. When targeted, such persons are known as Specially Designated Nationals (SDNs). OFAC-targeted foreign countries and regimes are excluded from trade and business with the United States.

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Iran Sanctions: Wiring Funds Sanctions Compliance Issues

Can Attorneys Represent Companies Santioned by the United States? Contingent upon the scope and form of legal services and the purpose of the legal services, it is likely that an attorney is able to represent a person or entity in a sanctioned country or a person or entity that has personal or commercial ties to a sanctioned country.

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U.S. Withdrawal from the JCPOA

Companies are advised to use the legal mechanisms in their contracts with Iranian entities to cease business activity during their respective wind-down period. The wind-down obligations, however, do not apply to various exemptions to trade sanctions on Iran in place prior to and after the JCPOA, such as trade with Iran on medical, agricultural

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Nicaragua Sanctions Daniel Ortega Rosario Murillo

In late 2018, the U.S. imposed financial sanctions on Nicaragua’s Vice President Rosario Murillo, President Daniel Ortega, and Nicaragua’s Bank Corp pursuant to Executive Order 13851. The United States claims that the Ortega government is corrupt, and human rights and anti-democratic activities in Nicaragua have resulted in a crisis.

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Venezuela Sanctions New OFAC General Licenses

Venezuela Sanctions | New OFAC General Licenses. On January 28th, OFAC designated Petroleos de Venezuela S.A., which is Venezuela’s national oil and natural gas company. The PdVSA, as it is known, was placed on OFAC’s Specially Designated Nationals and Blocked Persons List, or the SDN List, pursuant to E.O. 13850.

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Is the SDN List Public

OFAC Attorney: Yes. The SDN list is publicly available so that U.S. persons, banks, and financial institutions can identify and evaluate whether they are prohibited from transacting with a particular person. A typical entry on the SDN list publicly identifies the designated person’s name, aliases, addresses, citizenship, passport and other identification numbers, and the country of residence

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General License Transactions in Syria US Approved Transfers

General License Transactions in Syria. Charitable activities in relation to Syria is under General License 11 which is entitled to authorizing certain services in support of NGO or Non-Governmental Organization committees in Syria dating back to September 26, 2011. This General License states that NGOs are permitted to support not-for-profit

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US Sanctions on Syria

Furthermore, these Syria sanctions have also levied considerable restrictions on Americans seeking to invest in and do business with Syria. In accordance with Executive Order 13582 (pdf), US persons are prohibited from: Investing in Syria, wherever located. The direct or indirect exportation , sale, or supply, of any services to Syria.

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