persons may violate these laws unknowingly by embarking on business transactions with third parties who are representatives of or suppliers to persons with whom U.S. banks and nonbanks and their domestic and foreign subsidiaries, including remittance providersĪny person in the above categories must have solid OFAC compliance programs in place.transportation, including shipping companies, freight forwarders and travel agents.export of goods, including virtual goods and software.citizen, including corporations and their corporate affiliates and subsidiaries abroad, engaged in the following lines of business: economic sanctions statutes like those that have blocked transactions with Iran generally apply to “U.S. The Department of the Treasury’s Office of Foreign Assets Control (OFAC) enforces the statues, regulations and executive orders through which the United States imposes economic sanctions. economic regimes will continue to govern transactions with states such as Syria and Cuba, and others will block deals with individuals and groups in Russia, Palestine, and those involved in narcotics trafficking, human trafficking, and proliferation of weapons of mass destruction (WMD) activities. Many economic sanctions statutes, regulations, and executive orders will continue to govern transactions with Iran after the implementation date, likely some time in 2016. Trope’s August 2015 article in Business Law Today, with the JCPOA and the still-outstanding Joint Plan of Action (JPOA), the devil is in the details. and UN economic sanctions has been in the news since the July 14, 2015, conclusion of the Joint Comprehensive Plan of Action (JCPOA), signed between Iran and the G-5 +1 group.
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