If you conduct business overseas or have foreign investors in your funds, you are checking the various block persons lists to ensure you’re not working with bad guys. (You are checking, right.) The Office of Foreign Assets Control (“OFAC”), of the U.S. Department of the Treasury, has created two new lists: the Foreign Sanctions Evaders List and the Blocking Property of Additional Persons Contributing to the Situation in Ukraine.
Foreign Sanctions Evaders List
The FSE List implements Executive Order 13608 by identifying non-U.S. persons and entities that have engaged in conduct evading U.S. economic sanctions with respect to Iran or Syria. The FSE-listed individuals or entities are not necessarily located in Iran or Syria.
You are generally prohibited from all transactions or dealings, direct or indirect, involving persons or entities identified on the FSE List related to any goods, services, or technology (i) in or intended for the United States, or (ii) provided by or to U.S. persons, wherever located. However, unlike the OFAC Specially Designated Nationals List, the new FSE List does not require blocking of property and reporting of transactions with FSE-listed entities.
OFAC has elected to maintain a separate FSE List rather than include the FSE entries on the Specially Designated Nationals List. That means you need to screen against both lists. Most likely, you are using software or a third-party service provider, so check to make sure the FSE List was added to the screening protocol.
Blocking Property of Additional Persons Contributing to the Situation in Ukraine
By Executive Order on March 20, 2014, President Obama put in place new restrictions on companies and individuals that operates in sectors of the Russian Economy that would support the Russian Federation’s annexation of Crimea. It’s an expansion of 13660 and 13661.
So far, the orders have brought sixteen Russian government officials, members of the Russian leadership’s inner circle, and a Russian bank into the sanctions regime. Bank Rossiya (ОАО АБ РОССИЯ) is the personal bank for senior officials of the Russian Federation.
OFAC has added the blocked persons to the Specially Designated Nationals List. I received a notice that my vendor has already included the names in its database.
- Foreign Sanctions Evaders List
- Blocking Property of Additional Persons Contributing to the Situation in Ukraine
Image of villain is a caricature by J.J. McCullough