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ARTICLE · 01 APRIL 2014

One More List: OFAC’s Foreign Sanctions Evaders List

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U.S. companies and persons must take actions necessary to ensure that they screen effectively against, and do not engage in activities involving, parties included on the FSE list.

United StatesInternational Law

On February 6, 2014, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) published notice that it was listing eleven named parties as "Foreign Sanctions Evaders," pursuant to Executive Order 13608 (May 1, 2012) (the "FSE" list) (see http://www.treasury.gov/ofac/downloads/fse/fselist.pdf).  The action reflects new focus by OFAC on its authority to sanction individuals and entities determined by the U.S. government to have violated, attempted to violate, conspired to violate or caused to violate U.S. sanctions against Syria or Iran. U.S. persons and companies are prohibited from engaging in transactions with parties included on the FSE list unless the transaction qualifies for an exemption from OFAC sanctions under the International Emergency Economic Powers Act (IEEPA), or is otherwise specifically licensed by OFAC. Furthermore, the prohibition may in effect extend to foreign subsidiaries and controlled affiliates to the extent there is U.S. parent

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