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Financial Services Law Insights and Observations

OFAC amends Somalia Sanctions Regulations

Financial Crimes OFAC Department of Treasury Sanctions Somalia Of Interest to Non-US Persons OFAC Designations

Financial Crimes

On April 27, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced amendments and reissued the Somalia Sanctions Regulations in its entirety to further implement an April 2010 Somalia-related executive order (E.O. 13536), and to implement a July 2012 Somalia-related executive order (E.O. 13620). The final rule “replaces the regulations that were published in abbreviated form on May 5, 2010 and includes additional interpretive and definitional guidance, general licenses, statements of licensing policy, and other regulatory provisions that will provide further guidance to the public.” Updates include new section 1(a) of E.O. 13536, as amended by E.O. 13620, which blocks, with certain exceptions, “all property and interests in property that are in the United States, that come within the United States, or that are or come within the possession or control of any United States person of: (i) the persons listed in the Annex to amended E.O. 13536; and (ii) any person determined by the Secretary of the Treasury, in consultation with the Secretary of State. . .to have engaged in acts that directly or indirectly threaten the peace, security, or stability of Somalia. . . .” The final rule takes effect April 28.

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