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12 Sep 2017
Published in Article

US sanctions: you’re on your own

A call to OFAC’s Hotline revealed that no designations would be forthcoming, and that it was up to U.S. persons to identify all elements of the government (plus 50 Percent Rule holdings) and their securities issues. There is no longer any de minimus way for even the smallest firms or those with minimal overseas exposure to maintain any level of compliance through reliance on OFAC’s published lists.