Law360, New York (October 12, 2010, 10:40 AM EDT) -- The majority of recent sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) are so-called “list-based” programs, which are narrowly targeted and are not territorial in nature. They do not apply to the country as a whole and do not target its government.
Examples of these include, but are not limited to, programs such as the Balkans, Belarus, Cote d’Ivoire (Ivory Coast), Democratic Republic of the Congo, Somalia and Zimbabwe.
These sanctions prohibit “U.S. persons” from engaging in virtually...
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