OFAC DIRECTIVE 1 AS AMENDED SEPTEMBER 29, 2017

Business Update | October 11, 2017 | Author: Hdeel Abdelhady | PDF OFAC Further Tightens Russia Debt Prohibitions Pursuant to the Countering Russian Influence in Europe and Eurasia Act of 2017 As required by the Countering Russian Influence in Europe and Eurasia Act of 2017 (CRIEEA),[i] the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) on September 29, 2017 amended and reissued OFAC Directive 1 (Directive 1).[ii] As amended, Directive 1 continues to prohibit certain “new” debt, equity, and related transactions involving entities subject to U.S. Sectoral Sanctions targeting Russia’s financial services sector. This Business Update discusses the background to and mechanics of Directive 1 as amended and reissued. Ukraine/Russia-Related… Read More

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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 of State and local governments to adopt and enforce measures restricting investment in business enterprises in Iran, and for other purposes.” Among other measures, the House Bill would expand U.S. states’ authority to impose indirect Iran sanctions by excluding or debarring from state procurement and investments parties that do business in or with Iran, where… Read More

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MassPoint works collaboratively with clients to help them anticipate and manage legal, commercial, and reputation risk; solve legal problems; and advance strategic objectives. The Firm's services are described below. For additional information, please contact Hdeel Abdelhady at habdelhady@masspointpllc.com. MATTER MANAGEMENT AND FEE STRUCTURES  A successful engagement is measured not only by results, but also by process. MassPoint works with clients at the outset of engagements to properly connect its work to clients' business and objectives, manage matters efficiently, and identify one or more fee structures that are suitable for both the client and the Firm. Regulatory Counseling and Compliance Anti-Money Laundering (AML) Counter-Terrorism Financing (CFT) Due Diligence (Politically Exposed Persons… Read More

State Enforcement of OFAC Sanctions Against Banks

Special Issue Brief July 28, 2016 About this Publication This publication summarizes issues discussed in a forthcoming publication by Hdeel Abdelhady. It stems from ongoing work on key issues in U.S. law and its extraterritorial reach. For information about the issues discussed herein or MassPoint’s services, please contact Hdeel Abdelhady at  habdelhady@masspointpllc.com. 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 violations, such as of the… Read More

Proposed Rule Requires Banks to Collect Beneficial Ownership Information

PDF Download   Key Points Properly understood, “bank secrecy,” in the U.S. legal and regulatory context, facilitates disclosure; it does not afford secrecy. The proposed rule’s customer due diligence requirements fit within the U.S. Bank Secrecy Act/Anti-Money Laundering framework. The beneficial ownership requirement of the proposed rule, if adopted in final form, would to an extent align U.S. customer due diligence mandates with the beneficial ownership provisions of the FATF Recommendations, as revised in 2012. If adopted in final rule form, the proposed rule will take effect as a final rule one year after its effective date. Publication Information: Hdeel Abdelhady, Butterworths Journal of International Banking and Financial Law, November… Read More