It has been reported that OFAC has decided to waive a $385m penalty imposed on Zimbabwe’s CBZ Holdings in 2017. A cautionary letter was issued after OFAC finished a review of 15,000 transactions carried out by CBZ from 2009 to 2014 on behalf of ZB Bank, which was US-designated at the time.
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Maya Lester KC is a senior barrister (King’s Counsel) at Brick Court Chambers with a wide-ranging practice in public law, European law, competition law, international law, human...