OFAC has sanctioned, pursuant to Executive Order 13818 (asset freeze and travel ban), members of a South African family, Ajay, Atul and Rajesh Gupta, and their business associate Salim Essa for engaging in “significant corruption”. Sigal Mandeleker, Treasury Under Secretary for Terrorism and Financial Intelligence, said that the family “leveraged its political connections to engage […]

Further emphasizing its expectation that all companies whose business touches on the United States should maintain a robust, risk-based US economic sanctions compliance program (“SCP”), the US Treasury’s Office of Foreign Assets Control (“OFAC”) has published a detailed “Framework for OFAC Compliance Commitments” (the “Framework”) setting forth the key components of an adequate SCP. OFAC’s […]

The following may be of interest and a good time to refresh on the “Substance” issues and requirements General matters 1. In the General Secretariat’s report published yesterday, each of the Cayman Islands and the BVI were recognised for their cooperation and positive dialogue in respect of their economic substance requirements, and remain committed to […]

Content: The JEP Story OFAC and what happened last Friday? Sanctions and US law Why regulated business should take this seriously Closing thoughts Ask any questions The JEP Story The US Treasury has applied strict penalties, including asset freezes and a ban on dealing with American citizens, against seven Russian oligarchs, 12 companies they own […]