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Expert Analysis

Challenging OFAC Sanctions And Civil Penalties In US Courts

By Kenneth Linzer, Xingjian Zhao, Sebastian Soto and Javier Coronado Diaz (October 15, 2019, 5:33 PM EDT) -- The U.S. Department of the Treasury's Office of Foreign Assets Control[1] has near-plenary authority to impose the so-called economic death penalty, by adding foreign persons and entities to, among others, its List of Specially Designated Nationals and Blocked Persons, or SDN list.[2] This power continues to grow. In 2019, President Donald Trump created new grounds, whereby one can be listed by OFAC in connection with the agency's programs of sanctions related to regimes in Venezuela, Russia and Iran....

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