Genesis Asset Managers (GAM)

By: Thad McBride, Reid Whitten, and Cheryl Palmeri

On May 21, the U.S. Treasury Department Office of Foreign Assets Control (OFAC) announced a small but noteworthy enforcement settlement: a fine against a U.S. investment fund because the foreign subsidiary of that fund purchased Iranian securities.  It appears that OFAC’s enforcement action was not based on “facilitation” of a prohibited transaction with Iran, but rather on the U.S. parent’s failure to maintain sufficient controls to prevent its foreign subsidiary from conferring an economic benefit to Iran.  As a result, the U.S. investment manager, Genesis Asset Managers LLP (GAM US) will pay a civil penalty of $112,500.  
Continue Reading OFAC’s (Very) Long Arm: GAM Settlement May Illustrate the ITR’s Expanding Reach