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Financial Services Law Insights and Observations

OFAC sanctions more Bulgarian officials

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

Financial Crimes

On February 10, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 13818, against five current or former Bulgarian government officials for their alleged “extensive involvement in corruption in Bulgaria.” The designations build upon previous OFAC sanctions taken against three individuals and their networks (encompassing 64 entities) for their extensive roles in corruption in Bulgaria. (Covered by InfoBytes here.) As a result of the sanctions, all property and interests in property belonging to the sanctioned persons that are in the U.S. or in the possession or control of U.S. persons are blocked and must be reported to OFAC. U.S. persons are generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. Additionally, “any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked.” U.S. persons are also generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons unless authorized by a general or specific license issued by OFAC. “[F]inancial institutions and other persons that engage in certain transactions or activities with the sanctioned entities and individuals may expose themselves to sanctions or be subject to an enforcement action,” OFAC warned.