A recent Export Compliance Daily article cited a LawFlash authored by partner Kenneth Nunnenkamp and associate Eli Rymland-Kelly that discusses a recent large US sanctions penalty imposed by the Office of Foreign Assets Control (OFAC), highlighting growing compliance expectations for investment firms, accountants, lawyers, and other financial “gatekeepers.”
Drawing from the firm’s LawFlash, the article notes that the large penalty shows that fund managers “cannot ignore the source of funds,” and the owner of any assets, if they’re dealing with a representative known to be acting on behalf of a sanctioned person. Indeed, the manager “must treat those assets as blocked property, even if there are multiple intermediary entities.”
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