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Financial Services Law Insights and Observations

OFAC updates SDN List

Financial Crimes OFAC Department of Treasury SDN List Sanctions Of Interest to Non-US Persons OFAC Designations Russia

Financial Crimes

On February 22, the U.S. Treasury Department’s Office of Foreign Assets Control added two entities to its Specially Designated National List pursuant to the Countering America’s Adversaries Through Sanctions Act (CAATSA). One of the added entities has been designated pursuant to CAATSA Section 235, which provides the president with the authority to, among other things, “prohibit any transfers of credit or payments between financial institutions or by, through, or to any financial institution, to the extent that such transfers or payments are subject to the jurisdiction of the United States and involve any interest of the sanctioned person” or “prohibit any United States person from investing in or purchasing significant amounts of equity or debt instruments of the sanctioned person.”

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