On 9th October, Holland & Hart LLP published an article saying that OFAC has implemented President Trump’s prior revision of the definition of “significant transnational criminal organization” by eliminating a key clause that restricted the definition’s scope to largescale criminal syndicate organisations such as The Brothers’ Circle, Camorra, Yakuza, and Los Zetas, and which may eventually prove to be a significant development.  The article says that OFAC appears to have vastly expanded the universe of entities that may fall within the definition’s reach to include legitimate companies and organisations accused of criminal wrongdoing involving multiple countries.  The article also notes that OFAC has expressed its intent to provide “additional interpretative and definitional guidance” on this subject.   The revised definition is –

“a group of persons that includes one or more foreign persons; that engages in or facilitates an ongoing pattern of serious criminal activity involving the jurisdictions of at least two foreign states, or one foreign state and the United States; and that threatens the national security, foreign policy, or economy of the United States”.


This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at https://www.buymeacoffee.com/KoIvM842y

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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