Comments on: From The Department of Questions That Should Have Been Answered Already http://www.exportlawblog.com/archives/295 Latest News on DDTC, BIS, OFAC, and other export law matters Thu, 29 Jul 2010 15:45:32 +0000 hourly 1 http://wordpress.org/?v=3.0 By: Ex-OFAC http://www.exportlawblog.com/archives/295/comment-page-1#comment-8185 Ex-OFAC Thu, 21 Feb 2008 21:05:52 +0000 http://www.exportlawblog.com/archives/295#comment-8185 The problematic nature of this guidance is shown by the 2/21 blocking of Rami Makhlouf in the Syria corruption program. Treasury's press release says he's a businessman active in a number of industries, but there's no designation of any business he owns 50% or more in. So banks, insurance firms, exporters, and others have to scramble now to figure out what those businesses are and the extent of Makhlouf's ownership, and then -- if they meet the test in the guidance -- put these names into their software for screening customers' names. The Treasury Department could presumably have shared the names of the target businesses in companion designations when it designated Makhlouf, which would have made the Syria program more effective on the first day of his blocking. Now, it will be days before the review of ownership can be done by all the private sector players individually (another unfunded mandate) and cleared off on by their counsel. Will there be any blockable assets of the Makhlouf businesses left in U.S. financial institutions by the time the names under the blocking guidance are put into the screening software? Your tax dollars at work... The problematic nature of this guidance is shown by the 2/21 blocking of Rami Makhlouf in the Syria corruption program. Treasury’s press release says he’s a businessman active in a number of industries, but there’s no designation of any business he owns 50% or more in. So banks, insurance firms, exporters, and others have to scramble now to figure out what those businesses are and the extent of Makhlouf’s ownership, and then — if they meet the test in the guidance — put these names into their software for screening customers’ names.

The Treasury Department could presumably have shared the names of the target businesses in companion designations when it designated Makhlouf, which would have made the Syria program more effective on the first day of his blocking. Now, it will be days before the review of ownership can be done by all the private sector players individually (another unfunded mandate) and cleared off on by their counsel. Will there be any blockable assets of the Makhlouf businesses left in U.S. financial institutions by the time the names under the blocking guidance are put into the screening software?

Your tax dollars at work…

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