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February 6, 2014

Identification of Foreign Sanctions Evaders and the Publication of a New Foreign Sanctions Evaders List

The Treasury Department has announced the introduction of the Foreign Sanctions Evaders List (FSE List) to identify foreign persons sanctioned under Executive Order (E.O.) 13608, "Prohibiting Certain Transactions With and Suspending Entry Into the United States of Foreign Sanctions Evaders With Respect to Iran and Syria."

The FSE list includes persons sanctioned pursuant to E.O. 13608 for engaging in conduct relating to the evasion of U.S. economic and financial sanctions with respect to Iran or Syria, which are identified, respectively, with the program tags [FSE-IR] and [FSE-SY]. U.S. persons are generally prohibited from all transactions or dealings, whether direct or indirect, involving persons identified on this FSE List in or related to any goods, services, or technology (1) in or intended for the United States, or (2) provided by or to United States persons, wherever located. As a result, transactions by U.S. persons or through the United States are prohibited if they involve the provision or procurement of goods or services, including financial services, or technology to or from a person on the FSE List without authorization from OFAC, unless the transaction is otherwise exempt from regulation under the International Emergency Economic Powers Act (e.g., certain travel-related transactions).

Details on the list are found in the Treasury announcement.

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