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Financial Services Law Insights and Observations

OFAC sanctions BiH official and entity

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

Financial Crimes

On January 5, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, the first designations under Executive Order 14033, against an individual and one entity under that individual’s control in response to corrupt activities and ongoing threats to the stability and territorial integrity of Bosnia and Herzegovina (BiH). According to OFAC, the designated individual has used his official BiH position to accumulate personal wealth through graft, bribery, and other forms of corruption and has undermined BiH institutions by attempting to unilaterally transfer state competencies from the BiH government, among other things. As a result of the sanctions, all property and interests in property of the sanctioned individual subject to U.S. jurisdiction are blocked and must be reported to OFAC. OFAC noted that its regulations generally prohibit U.S. persons from participating in transactions with the designated person, 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.”