OFAC revised guidance on sanctions against the Iranian financial
sector.
In two new FAQs, OFAC explained that:
the prohibitions under Executive Order 13902 ( EO ),
including provisions creating potential exposure to secondary
sanctions, generally do not apply to transactions related to the
conduct of official business of the United Nations, its agencies
and certain other international organizations (FAQ 855); and
transactions related to certain legal proceedings, including
the defense of individuals in legal actions brought by the
Government of Iran, may be authorized under the Iran Transactions
and Sanctions Regulations, provided that such transactions do not
involve persons designated to OFAC s Specially Designated
On September 2, under Executive Order 13928, the “Executive Order on Blocking Property Of Certain Persons Associated With The International Criminal Court,” US officials added Fatou Bensouda, the ICC prosecutor, and Phakiso Mochochoko, the head of a division within the prosecutor’s office, to the Specially Designated Nationals and Blocked Persons List (the SDN List). This list is maintained by the US Department of Treasury’s Office of Foreign Assets Control (OFAC).
Their designation had two immediate effects. First, any property held by Bensouda and Mochochoko (or the property of any entity of which they own 50 percent or more) in the United States became “blocked.” Although any property they might have in the US has not been seized, they would not be able to exercise any rights over it, including use or sale. In addition, US persons or entities located anywhere in the world would not be able to transact with or provide services to either Bensouda or Mochochoko, unless t
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