By Maya Lester QC & Michael O’Kane

OFAC – all persons subject to US jurisdiction must comply with reporting requirements

OFAC has published 2 new FAQs relating to the July 2019 amendments to the Reporting, Procedures and Penalties Regulations (RPPR), which revised the reporting and recordkeeping requirements for those holding blocked assets, see post. FAQ 819 clarifies that all US persons and those subject to the US jurisdiction, including parties that are not US financial institutions, are expected to comply …

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About Michael O'Kane

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Michael is Senior Partner at Peters & Peters LLP. He has acted in many of the most high profile and sensitive business crime cases of the last 25 years, at Peters & Peters LLP...

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