This month our K2 Integrity experts answered our user-submitted compliance questions on China, sanctions, and the U.S. AML Act.
- In relation to Huawei, China is irreverent in the face of criticism and sanctions. How much room is there for diplomacy in addition to sanctions to effect change or is this simply wishful thinking?
- Will we see secondary sanctions imposed on financial institutions under the Hong Kong Autonomy Act?
- Will human rights will be the key theme for Hong Kong and China-related sanctions?
- Will China’s technology sector be targeted based on security concerns either by OFAC or Commerce Department?
- If sanctioned company A owns 70% of company B, and company B owns 70% of company C, and there are no other sanctioned ownership interests, is company C not sanctioned because company A only owns 49% of company C?
- How will FinCEN’s Advance Notice of Proposed Rulemaking on beneficial ownership reporting impact the financial services industry?
- Could you briefly discuss some key developments coming out of the U.S. Treasury Department?
- What is the legal basis and rationale of the new OFAC Directive addressing certain non-ruble denominated loans and bonds? The Executive Order issued last week seems to be providing the Secretary of the Treasury with asset freezing sanctions authority the against instrumentalities of the Russian government. Yet, we see a jump from asset freezing restrictions to these limited restrictions.
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