Assets Control ("OFAC") administers and enforces economic and trade sanctions based on United Sta... more Assets Control ("OFAC") administers and enforces economic and trade sanctions based on United States ("U.S. ") foreign policy and national security goals. These sanctions are imposed upon targeted foreign countries and regimes, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, terrorists, as well as other threats to the national security, foreign policy, or economy of the United States. Pursuant to Presidential national emergency powers, as well as authority granted by specific statutes, OFAC has the authority to prohibit transactions and freezes assets subject to U.S. governmental jurisdiction. 1 To carry out its mission, OFAC publishes a list of targeted countries, including those with state-sponsored terrorism and also, periodically publishes names on a list referred to as the "Specifically Designated Nationals" ("SDN") List to enforce U.S. sanctions aimed at individuals and entities. All U.S. entities, including casinos and card clubs, must take reasonable steps to prevent illicit transactions being conducted with targeted countries and SDNs. This paper discusses the OFAC sanctions programs related to country embargoes as well as the SDN List. Additionally, this paper discusses measures that may assist U.S. casinos and card clubs to better comply with OFAC regulations pertaining to customers or targeted countries. This paper focuses solely on the gaming side of the casino business. Nonetheless, the casino industry needs to understand that the non-gaming side of its business has exposures to OFAC requirements such as casino hotels and high-end retail stores (e.g., jewelry). Please note that there are three sections of this paper that also would apply to the non-gaming side of a casino's corporate business (i.e., "Who Is Required to Comply With OFAC Requirements, " "What OFAC Programs Exits, " and "OFAC Civil and Criminal Penalties"). Finally, to further assist readers, this paper provides 29 references/Web links to specific documents or Web sites so that readers can do further research if they wish.
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Papers by Leonard Senia