NEW OFAC REGULATION REQUIRES ALL US COMPANIES DEALING WITH FOREIGN CLIENTS TO MAINTAIN A SANCTIONS COMPLIANCE PROGRAMME

On 22nd October, Kenneth Rijock in his blog claims that an Interim Final Rule will, in effect, require ALL companies that buy or sell goods and services to foreign entities or individuals to create, and maintain, an effective AML/CFT compliance programme.  While the Rule does not specifically require such a programme, he concedes, he recommends that the only prudent response to its impact is to create one forthwith, to protect your company, not just those engaged in the delivery of financial services.

https://www.treasury.gov/resource-center/sanctions/Documents/fr84_29055.pdf

http://rijock.blogspot.com/2019/10/new-ofac-regulation-required-all-us.html

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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