Tag Archives: investment

Those Three Little Words: OFAC’s Subtle Language Shift Could Create Sweeping Change on Iran Investment

Article Highlights: Non-U.S. banks can do business with Iran and continue their relationships with U.S. banks. Non-U.S. companies may use proceeds from Iran transactions more freely, including in the United States. OFAC draws a clearer line with respect to the use of Iran-related funds. After the Iran nuclear agreement, as non-U.S. companies entered into newly-permitted … Continue Reading

OFAC’s (Very) Long Arm: GAM Settlement May Illustrate the ITR’s Expanding Reach

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
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