Because of recent events in the Ukraine, the U.S. Government has made changes to the Office of Foreign Assets Control (OFAC) list, including the addition of hundreds of Russian individuals and entities to the “List of Specially Designated Nationals and Blocked Persons” (“SDN List”), as well as a series of rules regarding certain types of business conducted with certain Russian individuals and companies.
The newly adopted OFAC changes are complicated, and dealers are encouraged to consult with counsel if they have any questions about a particular individual or transaction. A memorandum with an overview of the OFAC rules and dealers’ obligations has been updated to include additional information about the recent changes outlined above.
NADA Regulatory Affairs