The Office of Foreign Assets Control (OFAC) of the U.S. Department of Treasury imposes various trade sanctions against certain nations, entities and individuals in order to implement U.S. foreign policy. The OFAC sanctions restrict the activities of “U.S. Persons”, which include citizens and lawful permanent residents (Green Card holders) and U.S. business entities wherever located, as well as foreign citizens and business entities operating in the United States.
The sanctions include a range of possible measures including blocking orders on assets of certain designated persons and entities to comprehensive restrictions against U.S. person involvement directly or indirectly in any business transactions involving a sanctioned nation, entity or individual.
Specifically, OFAC currently administers comprehensive sanctions, including an export ban, against Cuba and Iran and those countries’ governments. OFAC also currently maintains more limited sanctions against the Balkans, Belarus, Burma, Cote d’Ivoire, the Democratic Republic of the Congo, Iraq, Lebanon, Liberia, Libya, North Korea, Somalia, Sudan, Syria and Zimbabwe. OFAC also maintains a comprehensive list of specially designated nationals, that U.S. Persons are prohibited from dealing with. This list is available at http://www.treas.gov/offices/enforcement/ofac/sdn/sdnlist.txt. Accordingly, no U.S. person or entity wherever located should undertake any international activity involving non-U.S. entities or locations without considering whether the OFAC’s sanction program has been complied with.
Given the potential volatility in U.S ... (continued)