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Are you suggesting transitive sanctions? Or suggesting that this invalidates any sanctions regime?
by theptip 4y ago
Are you suggesting transitive sanctions? Or suggesting that this invalidates any sanctions regime?
- josephcsible 4y agoThe former.
- theptip 4y agoHow would that work? Businesses are liable if they trade with an entity that isn't on the OFAC list but turns out to be a shell company of a restricted entity? Each company needs to not only do KYB and ensure compliance with OFAC lists, but also somehow figure out UBOs for every customer too? Sounds like a lot of work to me, probably not viable for any but the biggest companies, and even they would struggle.