Ukraine/Russia Sanctions: OFAC Authorizes Derivatives Linked to Prohibited Debt and Equity Under OFAC Directives 1, 2 or 3

Ukraine/Russia Sanctions: OFAC General License No. 1B Authorizes Derivative Transactions Linked to Prohibited Debt Under OFAC Directives 1, 2 or 3 On November 28, 2017, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License No. 1B under Executive Order 13,662.[i] General License 1B authorizes “[a]ll transactions by U.S. persons, wherever located, and…

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Hdeel Abdelhady to Speak on Managing Money Laundering, Trade Sanctions, and Corruption Risks

MassPoint’s Founder and Principal, Hdeel Abdelhady, will speak at a program on managing money laundering, trade sanctions, and corruption risks in business. The program, entitled “Know Your Business Partners: A Must to Managing Money Laundering, Trade Sanctions, and Corruption Risks,” will take place on November 17, 2017 in Washington, D.C. at the American Bar Association Business Law…

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Hdeel Abdelhady Discussed the NYDFS Habib Bank Enforcement Action

MassPoint’s Founder and Principal, Hdeel Abdelhady, discussed the legal significance and potential commercial implications of the NYDFS’ enforcement action against Habib Bank at a time of correspondent banking derisking. Ms. Abdelhady stated that: “at any time, the loss a New York banking license and direct access to the U.S. financial system would be devastating, but the…

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House Bill Would Enhance U.S. States’ Iran Sanctions Authority

On July 26, 2017, a bill was introduced in the House that would bolster U.S. states’ authority to impose sanctions on parties that engage in certain business with or in Iran. The State Sanctions Against Iranian Terrorism Act, H.R. 3425, would “amend the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 to secure the authority…

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Do State Regulators Like the NYDFS Have Authority to Enforce OFAC Sanctions?

Robust Enforcement of OFAC Sanctions by Federal Authorities In recent years the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and other federal authorities have robustly enforced OFAC-administered sanctions against banks, particularly U.S. branches of foreign banks. Notable for their number, successiveness, and monetary penalty amounts imposed—often for U.S. sanctions and related…

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Senate Bill to Combat ISIS Targets “Jurisdictions of Terrorism Financing Concern”

Senate Bill to Combat ISIS Targets “Jurisdictions of Terrorism Financing Concern” On February 13, 2017, Senator Bob Casey (D-PA) introduced in the Senate the “Stop Terrorist Operational Resources and Money Act” (the “STORM Act”). The purpose of the STORM Act is to “establish a designation for jurisdictions permissive to terrorism financing, to build the capacity…

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After Election 2016: 5 Legal and Business Issues to Watch in 2017

Download Infographic The dismantling of Obama-era laws and regulations, broader deregulation, and economic and political nationalism were and remain themes of the 2016 U.S. Election and presidential transition period. Donald Trump and members of the incoming Republican-controlled Congress have singled out for repeal or significant modification the Affordable Care Act (aka “Obamacare”) and the Dodd-Frank…
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