It is unusual to see a story where the National Basketball Association intersect with the U.S. Treasury’s Office of Foreign Assets Control. But that is the lot in life for the 7-foot-2 Hamed Haddadi, a back up center for the Memphis Grizzlies. Since Mr. Haddadi is from Iran, he is apparently subject to the decades [...]
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What You Need to Know About U.S. Sanctions Against Drug Traffickers
As part of OFAC‘s Specially Designated National List, OFAC includes narcotics kingpins. OFAC has published What You Need to Know About U.S. Sanctions Against Drug Traffickers (.pdf). On December 3, 1999, the President signed into law the Foreign Narcotics Kingpin Designation Act (the “Kingpin Act”), 21 U.S.C. § 1901-1908, 8 U.S.C § 1182. The related [...]
Updates to OFAC’s SDN List
FinCEN updated the SDN list with companies and individuals associated with the Mugabe regime in Zimbabwe: Treasury Designates Mugabe Regime Cronies. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today designated four Mugabe regime cronies and a number of entities owned or controlled by two of them. The financial and logistical [...]
Specially Designated Nationals and Blocked Persons List Updated
Here are the new bad guys on the OFAC’s Specially Designated Nationals list: AW-MOHAMED, Ahmed Abdi (a.k.a. ABUZUBAIR, Muktar Abdulrahim; a.k.a. AW MOHAMMED, Ahmed Abdi; a.k.a. “ABU ZUBEYR”; a.k.a. “GODANE”; a.k.a. “GODANI”; a.k.a. “SHAYKH MUKHTAR”); DOB 10 Jul 1977; POB Hargeysa, Somalia; nationality Somalia (individual) [SDGT] EL HABHAB, Redouane (a.k.a. “ABDELRAHMAN”), Iltisstrasse 58, Kiel 24143, [...]
Risk Factors for OFAC Compliance – Updated
OFAC has released a revised Risk Factors for OFAC Compliance in the Securities Industry on 11/05/2008. This release includes guidance regarding some specific risk factors relevant to firms in the securities industry.
Opening Securities and Futures Accounts from an OFAC Perspective
The Office of Foreign Assets Control published new guidance specific to the securities industry on 11/06/2008: Opening Securities and Futures Accounts from an OFAC Perspective A strong OFAC compliance program consists of procedures that are similar to those found in a brokerage firm’s Customer Identification Program (“CIP”). Firms should use risk-based measures for verifying the [...]
FATF on Money Laundering and Terrorist Financing Through the Real Estate Sector
The Financial Action Task Force published their report on Money Laundering & Terrorist Financing Thorugh the Real Estate Sector (June 29, 2007). I was disappointed in the report. I have a history of structuring complex real estate transactions. The report did little to help distinguish between legitimate and illegitimate structures. All of the structures and [...]
Specially Designated Nationals and Blocked Persons List Updated
The Office of Foreign Assets Control has just updated the Specially Designated Nationals and Blocked Persons List. It is a big list. The .pdf file is 404 pages long. The separate file of additions in 2008 is 106 pages long. Here are the new bad guys added on October 30, 2008: ABDELRAHIM, Abdelbasit (a.k.a. ABDUL [...]
The Specially Designated Nationals List (SDN)
The Office of Foreign Assets Control in the Treasury Department keeps the Specially Designated Nationals List (SDN). The Specially Designated Nationals List is a publication of OFAC which lists individuals and organizations with whom United States citizens and permanent residents are prohibited from doing business.
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