Tag Archives: investment

Your Way-Too-Early Guide to North Korean Investment: Big Opportunities, Big Risks, and the Regulatory Guidance to Identify Both

I spent last week in Seoul talking to clients about the latest changes to U.S. trade and sanctions policy (as South Korea is one of Iran’s largest trading partners, it is understandable that some concerns have arisen there in May). Interestingly, a topic that came up often was how to reenter the North Korean market. … Continue Reading

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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