| “The sanctions
programs targeting SDNs are of great importance to members
of the real estate industry.” “There is
also an absolute prohibition against engaging in transactions
with individuals or entities on OFAC’s list of
Specially Designated Nationals and Blocked Persons (the
“SDN List”), named parties owned or controlled
by, or acting for or on behalf of, targeted governments
or groups such as international narcotics traffickers
or terrorists… The listing is considered partial
because every U.S. individual or organization engaging
in transactions with foreign nationals must take reasonable
care to make certain that such foreign nationals are
not owned or controlled by, or acting for or on behalf
of the targeted governments or groups.”
"Criminal violations of the statutes administered
by OFAC can result in corporate and personal fines of
up to $1 million per count and, in the case of individuals,
a maximum of 10 to 12 years in jail per count. OFAC
also has independent authority to impose civil penalties
from $11,000 to $275,000 per count depending upon the
sanctions involved.”
|
