Question
1: What are the benefits and disadvantages of using economic sanctions to regulate money laundering, terrorism, drug trafficking, and other international crimes? How might the
1: What are the benefits and disadvantages of using economic sanctions to regulate money laundering, terrorism, drug trafficking, and other international crimes?
How might the adoption of the 50% rule by OFAC in relation to its SDN list create tension between effective implementation of government policy on the one hand and the placement of undue burdens on American businesses and organizations who unwittingly transact with blocked entities on the other? How might these imbalances be addressed in practice?
Jonathan Masters, What Are Economic Sanctions?, August 7, 2017 Thomas McCarthy et al, Challenging Executive Actions Under the International Emergency Economic Powers Act, May 31, 2018, The National Law Journal 50 U.S.C. 1701 and 1702 BNP Paribus Settlement Agreement FFIEC, Special Procedures Overview (re section 5318A of the Bank Secrecy Act) David L. Hall and Dana Stepnowsky, OFAC Sanctions: Costly ... But Effective?, March 30, 2018, New York Law Journal Dept. of the Treasury, Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked, August 13, 2014 OFAC FAQs
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