OFAC and Private Funds

An SEC-registered investment adviser entered into a settlement agreement with the U.S. Treasury Department's Office of Foreign Assets Control for allegedly failing to maintain a compliance program. The problem was triggered when the adviser's foreign affiliate caused one of its clients to … Continue reading

Iran, Tuvalu, and Oil

Anyone who works with sanctions monitoring most likely hates ships. Their names are so common that the ships' names routinely cause false positives. (My software has a button to exclude ships' names, but I often forget to activate that feature.) Now the Iranian oil sanctions program is … Continue reading