OFAC fundamentals, what is the nomenclature of OFAC compliance; (Sectoral Sanctions, Secondary Sanctions, SDNs, blocking, rejecting, etcetera, etcetera). Communicating risk-based OFAC policies, monitoring practices and testing to your examiners; Why OFAC's sanctions are becoming a more important element in BSA exams. Alaska w10 pro driver download for windows.
OFAC designated two Burmese military holding companies, Myanma Economic Holdings Public Company Limited ('MEHL') and Myanmar Economic Corporation Limited ('MEC'), to the Specially Designated Nationals and Blocked Persons List (or 'SDN List'). Acer hs-usb diagnostics 33a0 (com62) driver download for windows 10.
The designations were pursuant to Executive Order ('EO') 14014 ('Blocking Property with Respect to the Situation in Burma'), which, as previously covered, authorizes the Treasury Secretary to sanction Burma's defense sector. According to OFAC, the two companies enjoy a 'privileged position' in the economy of Burma, and 'dominate' certain industries, including trading, natural resources, alcohol, cigarettes and consumer goods.
Concurrent with these designations, OFAC issued General License ('GL') No. 4, which authorizes, through June 22, 2021, transactions and activities ordinarily incident to the wind down of transactions involving MEHL, MEC or any entity owned by 50 percent or more by the two companies. In FAQ 883, OFAC clarified that, while GL 4 is in effect, covered wind down transactions may be processed through the U.S. financial system and otherwise may involve U.S. persons.
With respect to the situation in Burma, OFAC also issued GLs 1, 2 and 3, which authorize certain transactions prohibited by EO 14014 that are associated with, respectively, the official business of the United States Government, the official business of certain international organizations and the activities of certain nongovernmental organizations. In FAQ 882, OFAC clarified which organizations within the United Nations' programs are covered by GL 2.
Primary Sources
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Ofcom
- Office of Foreign Assets Control (OFAC) Office of the U.S. Treasury responsible for administering and enforcing U.S. Economic and trade sanctions. Credit unions are required to have a written, risk-based OFAC compliance program (often included in BSA/AML program). BSA and OFAC Compliance - Staff Training.
- Oct 01, 2020 OFAC. OFAC’s Economic Sanctions Enforcement Guidelines (Enforcement Guidelines)10 provide more information regarding OFAC’s enforcement of U.S. Economic sanctions, including the factors that OFAC generally considers when determining an appropriate response to an apparent violation.
- OFFICE OF FOREIGN ASSETS CONTROL CHANGES TO THE Specially Designated Nationals and Blocked Persons List SINCE JANUARY 1, 2020.
- OFAC does not provide recommendations with regard to the appropriateness of any specific confidence rating. Sanctions List Search is one tool offered to assist users in utilizing the SDN List and/or the various other sanctions lists; use of Sanctions List Search is not a substitute for undertaking appropriate due diligence.
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Braumiller Law Group, PLLC
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- Appendix A to Part 560 [Reserved]
- Appendix C to Part 560 [Reserved]