(3) are owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, such entities or persons. (2) have facilitated deceptive transactions for or on behalf of persons subject to U.S. sanctions against Syria or Iran, including sanctions imposed under counter-proliferation or counter-terrorism authorities (1) have violated, attempted to violate, conspired to violate or caused a violation of U.S. The FSE list implements presidential Executive Order 13608, “Prohibiting Certain Transactions With and Suspending Entry Into the United States of Foreign Sanctions Evaders With Respect to Iran and Syria.” Pursuant to the Executive Order, the list identifies parties that the U.S. government at Consequently, companies must take care to ensure that their screening practices, whether conducted manually or in reliance on commercial screening software services, covers this list. However, the FSE list is not currently incorporated into the Consolidated Screening List made available by the U.S. parent company involvement in their transactions. While not previously a focus of OFAC enforcement, this development underscores the need for companies to add the FSE list to the collection of other restricted-party lists that must be covered in routine compliance screening. Furthermore, the prohibition may in effect extend to foreign subsidiaries and controlled affiliates to the extent there is U.S. persons and companies are prohibited from engaging in transactions with parties included on the FSE list unless the transaction qualifies for an exemption from OFAC sanctions under the International Emergency Economic Powers Act (IEEPA), or is otherwise specifically licensed by OFAC. government to have violated, attempted to violate, conspired to violate or caused to violate U.S. The action reflects new focus by OFAC on its authority to sanction individuals and entities determined by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published notice that it was listing eleven named parties as “Foreign Sanctions Evaders,” pursuant to Executive Order 13608 (May 1, 2012) (the “FSE” list) (s ee ).
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