On 25th May, OFAC published 2 new FAQ to provide guidance on US persons’ ability to receive payments of principal and interest from blocked persons listed in General Licenses 12C, 14 and 15 for a pre-existing loan or bond, and the sanctions implications for a foreign company paying dividends to a blocked person who is a minority shareholder.


Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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