U.S. Economic Sanctions Compliance for Non-U.S. Financial Institutions
DescriptionTCAE is excited to invite Nick Turner, a lawyer at Steptoe & Johnson in Hong Kong to share his insights on U.S. Economic Sanctions Compliance for Non-U.S. Financial Institutions. In this session, Nick will explain how U.S. economic sanctions administered by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) apply to the activities of non-U.S. financial institutions. Attendees will learn to spot transactions that involve the U.S. financial system and identify activities that are prohibited or that may continue to be permissible for non-U.S. financial institutions and their customers as part of their risk-based compliance programs. These principles will be illustrated using recent examples of OFAC sanctions targeting persons in Hong Kong and China, restrictions on securities of certain Chinese companies, and recent developments involving Cuba, Venezuela, and other sanctions targets.
- Understanding the basic features of U.S. sanctions administered by OFAC, including the key differences between blocking sanctions, sectoral sanctions, and primary and secondary sanctions
- Identifying accounts and transactions involving “U.S. persons” and the “U.S. financial system” that are subject to OFAC sanctions
- Understanding the basic features of recent U.S. sanctions targeting persons in Hong Kong and China, and securities of certain Chinese companies and their application to non-U.S. financial institutions and customers
- Distinguishing OFAC sanctions from licensing restrictions under the U.S. Export Administration Regulations (EAR)
- Reviewing OFAC’s expectations for risk-based compliance controls
- Looking ahead to emerging OFAC risks involving China, Myanmar, Russia, and other issues of interest to the new Biden administration