Columbia Law School Blog Publishes Akin Gump Article on Waked Sanctions

The CLS Blue Sky Blog, Columbia Law School’s blog on corporations and the capital markets, has published “Akin Gump discusses Tackling a Panamanian Money Laundering Organization,” written by international trade partner Jonathan Poling and counsel Anne Borkovic.

The article, which originated as an Akin Gump client alert, recounts the initiation of sanctions by the Treasury Department’s Office of Foreign Assets Control (OFAC) against 77 entities and individuals associated with the Waked Money Laundering Organization. Poling and Borkovic write, “OFAC stated that the designation was necessary to disrupt the organization’s alleged activities in laundering drug trafficking proceeds by using trade-based methods, duty-free retail, real estate development and financial services throughout the region.”

According to the authors, the Waked Sanctions, as they are known, “mean that U.S. Persons are generally prohibited in engaging in transactions with these entities and individuals. Further, U.S. Persons are required to block any assets of these individuals that are under their control.”

Looking ahead, Poling and Borkovic advise, “Companies should carefully review the names of the sanctioned entities to determine if they have any connections or business with them, including consideration as to whether the sanctioned entities directly or indirectly own a 50 percent or greater interest in any of the companies’ customers, vendors and other business partners. The legality of any ongoing interactions or future business will need to be carefully scrutinized, as well as whether the U.S. Persons have control over any assets that must be blocked.”

To read the entire client alert as it originally appeared, please click here.