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Financial Services Law Insights and Observations

OFAC sanctions Cuban officials

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

Financial Crimes

On July 30, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13818 against two Cuban individuals and one Cuban entity under the Global Magnitsky Human Rights Accountability Act. According to OFAC, the sanctions expand on Treasury’s July 22 designations by sanctioning additional persons in connection with actions to suppress peaceful, pro-democratic protests in that began on July 11 in Cuba (covered by InfoBytes here). As a result of the sanctions, all transactions by U.S. persons or in the U.S. that involve any property or interests in property of designated or otherwise blocked persons are generally prohibited. OFAC notes that its regulations generally prohibit U.S. persons from participating in transactions with these persons, which include “the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person or the receipt of any contribution or provision of funds, goods or services from any such person.”

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