Who Is in the Chain of Liability for OFAC Noncompliance?

By now many of us have either heard or read several articles written about compliance with the Executive Order 13224, titled "Blocking Property and Prohibiting Transactions with Persons Who Commit, Threaten to Commit, or Support Terrorism" (the "Executive Order"). Although the probability of leasing or selling to any "Persons Who Commit, Threaten to Commit, or Support Terrorism," is extremely low, the consensus among the real estate bar seems to be that it is better to comply with the Executive Order and protect yourself and your client rather than risk the stiff penalties and stigma that would follow by inadvertently violating it. It is apparent that the creation of a Landlord-Tenant relationship or a conveyance of a property interest would give rise to an obligation to comply with the Executive Order, thereby triggering all of the potential liability associated with violating it.

26 minute readMarch 31, 2005 at 10:01 AM
By
Michael S. Strauss
Thomas Pomella
Who Is in the Chain of Liability for OFAC Noncompliance?

By now many of us have either heard or read several articles written about compliance with the Executive Order 13224, titled “Blocking Property and Prohibiting Transactions with Persons Who Commit,

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