Richards Kibbe & Orbe –
As U.S. economic sanctions have tightened, sanctioned countries, entities and individuals are engaging in increasingly sophisticated practices to evade their impact. Recent reports in the media and by U.S. regulators have described complicated sanctions evasion schemes involving false documentation, front companies and other deceptive trade practices which appear to have succeeded in luring otherwise innocent U.S. parties into prohibited transactions.
In this alert, RK&O attorneys Michael D. Mann and Jamie A. Schafer review recent developments and OFAC’s evolving due diligence expectations.
Compliments of Richards Kibbe & Orbe – a member of the EACC in New York.