September 2014

Legal Update / 19.09.2014

US persons and companies are prohibited from doing business with blocked persons. On August 13, 2014 the Treasury Department's Office of Foreign Asset Control ("OFAC") issued revised guidance on its 50% rule for Entities Owned By Persons Whose Property and Interest in Property Are Blocked. This new guidance dramatically increases the vigilance and diligence necessary to verify that you are not doing business with an entity that is a blocked person.