THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

Issue 57, February 2017

OFAC guidance clarifies open questions on sanctions advice (to an extent…)

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By Doug Jacobson, Michael Burton and Glen Kelley, Jacobson Burton Kelley www.jbktradelaw.com   On 12 January, the Office of Foreign Assets Control (‘OFAC’) of the U.S. Department of the Treasury   published guidance ‘on the provision of certain services relating to the requirements of U.S. sanctions laws’ by U.S. persons, which aims to address a number of open questions in this regard. Essentially, all OFAC sanctions regulations contain general licences authorising legal advice to sanctioned governments, companies and individuals (‘sanctioned persons’) on the requirements of and compliance with U.S. law, and in connection with U.S. legal and administrative proceedings. These licences...

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