What should we do about the nuclear weapon program in Iran? The country is not complying with the Treaty on the Non-Proliferation of Nuclear Weapons. Iran has four main sites being used to create weapons-grade uranium. The country has stopped short of further purifying the uranium to the concentration needed for a bomb. But once … Read more »
Tag: Iran
New Lists to Check for Bad Guys
If you conduct business overseas or have foreign investors in your funds, you are checking the various block persons lists to ensure you’re not working with bad guys. (You are checking, right.) The Office of Foreign Assets Control (“OFAC”), of the U.S. Department of the Treasury, has created two new lists: the Foreign Sanctions Evaders List and … Read more »
Iran, Tuvalu, and Oil
Anyone who works with sanctions monitoring most likely hates ships. Their names are so common that the ships’ names routinely cause false positives. (My software has a button to exclude ships’ names, but I often forget to activate that feature.) Now the Iranian oil sanctions program is highlighting some issues with ships. The tiny Pacific … Read more »
Real Estate and OFAC Compliance
The tale of 650 Fifth Avenue is one that should be closely watched by compliance professionals dealing with real estate. Last year, the Department of Justice filed a forfeiture proceeding against a 40% interest in the property held by the Assa Corporation. They recently filed a forfeiture proceeding against the other 60% held by the … Read more »
Government Seizes 650 Park Avenue
According to the Wall Street Journal, the United States Attorney for the Southern District of New York has filed a forfeiture proceeding against 650 Fifth Avenue in New York. In its press release: United States files civil forfeiture action against ASSA corporation’s interest in Manhattan office tower (.pdf), the DOJ claims that a 40% interest … Read more »