OFAC has issued regulations to implement the Hizballah International Financing Prevention Act 2015, which became law on 18 December 2015. The regulations introduce secondary sanctions, which will prohibit or impose strict conditions on non-US financial firms accessing the US financial system if they are determined to have facilitated a transaction relating to Hizballah, or laundered money in connection with such a transaction. Secondary sanctions apply to non-US persons outside of the US.
OFAC’s SDN List has been updated, and now indicates that people and entities previously subject only to primary sanctions as Specially Designated Global Terrorists are now also subject to secondary sanctions under the new regulations. Details of the updates are here.
Michael was called to the Bar in 1992 and prior to joining Peters & Peters was a senior specialist prosecutor at the Crown Prosecution Service Headquarters (CPS). He was a key member of a small specialist unit responsible for the prosecution of serious and high-profile fraud, terrorist,...See profile for Michael O'Kane >