External guidance published by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has been added to the Sanctions Guidance website.
The Sanctions Advisory highlights sanctions risks arising from sham transactions used to evade sanctions and to identify factors to consider when evaluating whether assets may be the subject of a sham transaction. The guidance includes typologies and red flags to be aware of in relation to sham transactions (i.e. where sanctioned persons give up their assets of paper only, in an attempt to evade sanctions, while retaining their interest in those assets).
While this guidance has been published by OFAC, it does have relevance in relation to the sanctions imposed in the Isle of Man (UN and UK). Therefore, businesses in the regulated sectors may find this helpful when reviewing sanctions risk as part of your sanctions compliance programme.
This guidance does not represent legal advice. If you are unsure about your obligations in a given case, you should consider taking independent legal advice.
Failure to comply with financial and trade sanctions legislation or to attempting to circumvent its provisions is a criminal offence.
Further Information
Contact details for enquiries
If you require any further information or guidance, please contact the Sanctions Team on:
Telephone: +44 1624 648109
Email: sanctions@gov.im
Please note: We are unable to provide legal advice. You may need to seek independent legal advice.
