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  • OFAC issues Cambodia advisory; sanctions Cambodian officials

    Financial Crimes

    On November 10, OFAC published a Cambodia Business Advisory on High-Risk Investments and Interactions, which addresses two primary areas of risk exposure for U.S. companies: (i) illicit finance activities in Cambodia and related risks for certain sectors; and (ii) involvement with Cambodian entities connected to trafficking in persons, wildlife, and narcotics trafficking in Cambodia and associated risks for certain sectors.

    The same day, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13818 against two Cambodian government officials under the Global Magnitsky Human Rights Accountability Act. According to OFAC, the sanctioned individuals, among other things, allegedly conspired to inflate the cost of facilities at a Cambodian naval base and personally benefit from the proceeds. As a result of the sanctions, all property and interests in property belonging to the sanctioned entities subject to U.S. jurisdiction are blocked and must be reported to OFAC. Additionally, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” 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.”

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

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