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OFAC’s Recent Clarification on Counter Terrorism Sanctions

Following the recent trend of President Trump cracking down on terrorism overseas, Office of Foreign Assets Control (OFAC) has recently added new individuals and entities under the counter terrorism designation for Specially Designated Global Terrorist (SDGT's).

As of December 13, 2019, this updated list prohibits US. Citizens and permanent residents (regardless of their current location) from engaging in transactions involving information or informational materials, including artwork, that are the property or subject to an interest in property of persons designated.

These updates on OFAC's website is an important resource for people to be aware of, as engaging in business or transactions with known SDGT's can result in criminal punishments for the U.S. entities.

In the updated list of new individuals known to be SDGT's, the list names seem to follow the trend of President Trump's pressure on Iran and the middle east. Most of the names are of people and company entities are residing in countries such as Lebanon.

If you are unaware of the specific names and you think these sanctions would affect your business, it is highly advised to consult the list for specific details violations.

To make information more accessible to the public, OFAC has also added new information on their frequently asked questions under the topic of “counter terrorism sanctions”. OFAC specifically outlines three new points that they hope will clarify common points of confusion.

These new clarifications seem to mainly target the global art community, as OFAC explicitly addresses the possibility of engaging in art transactions with SDGT's. In one of the supplemental points, OFAC essentially outlines the necessary steps to take if an institution or individual finds themselves to be in possession or in transaction with a SDGT.

The main takeaway from the important updates OFAC publishes is the importance of adhering and respecting OFAC's blocking and sanctions. For international businessmen that conduct transactions in area with known OFAC sanctions, it is best to be up to date with the latest OFAC lists.

OFAC is ultimately an institution designed to protect the interests of Americans and should be consequently followed. For U.S. citizens and permanent legal residents (regardless of their current location), violating such sanctions can be punishable in the court of law.

This is an immigration legal blog. It is not intended to be used as legal advice.

For further information please contact the law offices of attorney Ramona Kennedy.

Ramona Kennedy (Attorney) received her Jurisprudence Doctorate in America and is a licensed attorney in California (USA). Ramona Kennedy is a member of American Immigration Lawyers Association (AILA). Ramona Kennedy is fluent in English and Farsi (reading & writing) & speaks Azeri Turkish.

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