On 19 March 2020, the US Treasury Department’s Office of Foreign Assets Control (OFACsanctioned five companies based in the United Arab Emirates (UAE), pursuant to Executive Order 13846 (EO 13846), for their alleged involvement in purchasing hundreds of thousands of metric tons of petroleum products from the National Iranian Oil Company (NIOC) for delivery to the UAE. The following UAE-based companies were added to the US Specially Designated Nationals and Blocked Persons List (SDN List): (1) Alam Althrwa General Trading LLC, (2) Alphabet International DMCC, (3) Alwaneo LLC CO, (4) Petro Grand FZE, and (5) Swissol Trade DMCC (together the Sanctioned Companies).

For more information and to view the full article, please visit our Baker McKenzie Sanctions Blog.

Should you have any concerns with regards to your global sanctions and anti-money laundering obligations and risks, please do not hesitate to contact our team.

Author

Terry Gilroy is a partner in the New York office of Baker McKenzie and a member of the Compliance and Investigations Practice Group. Prior to joining the Firm in 2018, Terry served as Americas Head of the Financial Crime Legal function at Barclays. Terry advises businesses and individuals on white collar and financial crime issues and has significant experience conducting investigations relating to compliance with the US Foreign Corrupt Practices Act (FCPA) and related bribery and corruption statutes, economic sanctions regulations as administered by the US Department of the Treasury's Office of Foreign Assets Control (OFAC), and the Bank Secrecy Act and related anti-money laundering (AML) regulations and statutes.

Author

Borys Dackiw is the Head of Compliance practice in the Gulf based in the Firm's Abu Dhabi office. A partner of Baker McKenzie since 1995, Borys regularly advises clients across various industries on their compliance and anti-bribery policies and programs and has participated in whistleblower interviews relating to allegations of bribery and other bribery-related investigations. He also advises on mergers & acquisitions (including privatizations), private equity and general corporate and commercial law.

Author

Mazen Boustany is the UAE Head of the Financial Regulatory, Policy & Legislative Group of Baker McKenzie Habib Al Mulla, based in Dubai. He has over 22 years' experience in banking and finance law in the Middle East, including financial services regulation, Islamic finance, structured finance, securitisation, private equity, financial structuring and restructuring, cross-border transactions and investment funds. Mazen has helped draft many of the financial regulations for the UAE Central Bank and Ministry of Finance.

Author

Samir Safar-Aly is an English-qualified senior associate in Baker McKenzie's DIFC office in the UAE, focusing on financial crime and financial regulation for the wider MENA region from both an advisory and investigations perspective. Samir's expertise includes UAE, Saudi and wider international anti-money laundering (AML) and counter-terrorist financing (CTF) rules, anti-bribery and corruption laws (covering the GCC, UK and U.S.) and other areas of white-collar and financial crime. He also advises governments in Africa and Asia on public policy and legal and regulatory reform. Samir has particular expertise in financial and economic sanctions and regularly provides guidance on UN, U.S. (OFAC), UK, EU and GCC sanctions regimes and export-control issues across a wide range of sectors. With regards to financial regulation, Samir covers the GCC and wider Middle East and provides guidance on the cross-border marketing of financial services and products, conduct issues and license applications. He regularly advises the world's leading financial institutions, asset managers, as well as FinTech start-ups.

Author

Laura Klick is a US-qualified associate in Baker McKenzie's London office, where she advises on a variety of trade and compliance matters involving US, UK, and EU export controls and economic sanctions. Laura regularly counsels individuals and multinational corporations on compliance, licensing, and enforcement matters involving the US Treasury, State, and Commerce Departments and assists clients in understanding and navigating the complex regulatory regime governing international trade and investment.

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