OFAC and Offshore in the US

OFAC and Offshore in the US

This is a new section for the Aegis Journal and will deal with Banking Secrecy Act, Anti- Money Laundering, and Office of Foreign Asset Control matters for all companies, not just banking, finance and insurance companies.

A young professional firm located in Cairo, Egypt was very excited when one of our editors visited with them last month.  An American firm owned their company, which specialized in accounting and compliance.  They had clients throughout the Middle East and North Africa (MENA) — including, Egypt, Syria, Iran and Sudan.  During our discussion I reminded them that using an American company as a form of branding and tax reduction made them subject to American sanctions related to commerce with Egypt, Syria, Iran and Sudan.  The group was very professional, they were doing good work, and were not likely to offer support and succor to the named states -– but they were in clear violation of the law.

A quick note for those who work internationally and choose to use the U.S. as an offshore location — U.S. law is a double-edged sword, it presents both opportunities and restrictions.  It’s best to be mindful of both, and consult with professionals who deal in these matters on a daily basis.  A simple phone call would have informed the firm that this type of arrangement – an Egyptian company, owned by a US company, transacting business with people, companies or in places that are on the OFAC sanctions list — would not be compliant.

For a quick overview please read –

http://www.treasury.gov/resource-center/sanctions/Documents/abamag.pdf

Shaun Hassett  —  [email protected]

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