UK's OFSI Issues Guidance on Avoiding Sanctioned Entities

The United Kingdom's Office of Financial Sanctions Implementation released a Dec. 17 guidance on determining whether a sanctioned entity is involved in a transaction. The guidance contains links to OFSI’s consolidated list and describes difficulties that may rise when screening certain companies, including complicated ownership stakes and the use of shell companies. The guidance details a case study involving the Libya African Investment Portfolio and the Libyan Investment Authority, two sanctioned entities with hotel subsidiaries that may avoid screening detection. The guidance also offers advice for steps to take after discovering a sanctioned entity in a transaction.