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ARTICLE · 23 AUGUST 2005

International Client Alert - August 2005

Powell Goldstein LLP
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In this issue: Department of Justice Pursues Criminal Investigation of DaimlerChrysler for Alleged FCPA Violations, Two Former Executives Sentenced to Jail Time for Violating The FCPA in Kay Case, BIS Amends CCL To Implement Understandings Reached at the August 2005 Australia Group Meeting, State Department Plans to Fine Boeing For Exports of Aircraft to China, Customs Set To Enforce New Restrictions on Wood Packaging.

United StatesInternational Law
Clif Burns
Clif Burns

New Guidance Released For OfAC Compliance By Financial Institutions

The Federal Financial Institutions Examination Council’s ("FFIEC") Bank Secrecy Act/Anti- Money Laundering Examination Manual (the "Manual") was recently updated, in cooperation with the Treasury Department’s Office of Foreign Assets Control ("OFAC") to include examination procedures to determine compliance with the regulatory scheme enforced by OFAC. OFAC administers and enforces sanctions based on U.S. foreign policy and national security goals against targeted individuals, governments and their officials. The Manual, as now revised, presents a risk-based analysis that could be said to depart somewhat from a strict application of OFAC regulations.

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