50 Percent Rule? Not for Nynas…
Removal of Venezuela-related General License 13E, Issuance of Venezuela-related General Licenses 3H and 9G, and Amended Frequently Asked Questions 5/12/2020 The Department of the Treasury’s Office of...
View ArticleOops and oops: American Express Travel Related Services Company gets Finding...
So, simply put, one of American Express’ home-grown applications had a bug in it (BTW, not in the actual matching software): On January 12, 2009, OFAC added Wisser to the List of Specially Designated...
View ArticleNKSPEA Boilerplate added to a ton of OFAC North Korean designations
North Korea Administrative Designations Updates 5/13/2020 Pursuant to the National Defense Authorization Act for Fiscal Year 2020, the North Korea Sanctions and Policy Enhancement Act (NKSPEA) was...
View ArticleThere is value in being explicit…
Even Mr. Watchlist learns something from time to time – and yesterday was a very visible example. When I looked at yesterday’s OFAC updates to a large number of North Korean sanctions designations, I...
View ArticleGet your terms straight, folks!
From OFAC: Guidance to Address Illicit Shipping and Sanctions Evasion Practices 5/14/2020 The U.S. Departments of State and Treasury, and the U.S. Coast Guard, issued a global advisory to alert the...
View ArticleMay 14, 2020: New Sanctions Advisory for the Maritime Industry, Energy and...
Yesterday, a new advisory was issued by the US State Department, Treasury Department and Coast Guard that consolidates and enhances the prior North Korea, Syria and Iran shipping advisories. It’s a...
View ArticleUS Shipping Advisory: Deceptive Shipping Practices
Deceptive Shipping PracticesApproximately 90 percent of global trade involves maritime transportation. Malign actors constantly seek novel ways to exploit global supply chains for their benefit. The...
View ArticleUS Shipping Advisory: General Practices
General Practices for Effective Identification of Sanctions EvasionAs industry actors implement appropriate due diligence and compliance programs based on their risk assessments, we recommend that...
View ArticleWhy does the 50 Percent Rule work the way it does?
As you may know, the OFAC 50 Percent Rule guidance says that entities owned by 1 or more sanctioned parties subject to the same types of sanctions (e.g. asset freezes, capital markets restrictions,...
View ArticleUS Shipping Advisory: Guidance for Maritime Insurance Companies
Guidance for Maritime Insurance CompaniesA maritime insurance company may wish to consider implementing the following diligence practices as appropriate in assessing and mitigating sanctions risks....
View ArticleUS Shipping Advisory: Guidance for Flag Registry Managers
Guidance for Flag Registry ManagersA flag registry manager may wish to consider implementing the following diligence practices to the extent it deems such practices appropriate and helpful in...
View ArticleUS Shipping Advisory: Guidance for Port State Control Authorities
Guidance for Port State Control AuthoritiesPort state control authorities and relevant customs authorities may wish to consider implementing the following due diligence practices to the extent they...
View ArticleUS Shipping Advisory: Guidance for Shipping Industry Associations
Guidance for Shipping Industry AssociationsShipping industry associations may wish to consider implementing the following due diligence practices to the extent they deem such practices appropriate and...
View ArticleUS Shipping Advisory: Guidance for Regional and Global Commodity Trading,...
Guidance for Regional and Global Commodity Trading, Supplier, and Brokering CompaniesRegional and global commodity trading, supplier, and brokering companies may wish to consider implementing the...
View ArticleOFAC designates Shanghai-based company under Iran & counter-terror sanctions
Earlier today, OFAC designated the following firm: SHANGHAI SAINT LOGISTICS LIMITED, Rm 910, 9/F, 650 Han Kou Road, Huang Pu District, Shanghai, China; Rm 930, Building C, Cifi Air Center, Shunyi...
View ArticleUS Shipping Advisory: Information Helpful to Financial Institutions to Assess...
Information Helpful to Financial Institutions to Assess the Risks of their Maritime Industry Customers Similar to the customer due diligence approach conducted for any customer, financial institutions...
View ArticleUS Shipping Advisory: Guidance for Ship Owners, Operators, and Charterers
Guidance for Ship Owners, Operators, and CharterersShip owners, operators, and charterers may wish to consider implementing the following due diligence practices to the extent they deem such practices...
View ArticleOFAC adds to Iran and CAATSA-Iran sanctions…
Today, OFAC added the following individuals: ALI NOORINAJAD, Mohammad, Iran; POB Kabudar Ahang, Iran; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male;...
View ArticleSo, here is the associated messaging…
Standing with the Iranian People PRESS STATEMENT MICHAEL R. POMPEO, SECRETARY OF STATE MAY 20, 2020 Share Today, the United States is imposing financial sanctions and visa restrictions on Iranian...
View ArticleUS Shipping Advisory: Guidance for Classification Societies
Guidance for Classification SocietiesClassification societies may wish to consider implementing the following due diligence practices to the extent they deem such practices appropriate and helpful in...
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