OFAC Takes Sanctions Jurisdiction Into Uncharted Waters

On February 3, 2017, the US Treasury Department’s Office of Foreign Assets Control issued a finding of violation against Taiwan-based B Whale Corp. (BWC), a member of the Taiwan-based shipping company TMT Group. The finding of violation was issued for activity occurring entirely outside the United States, based on the jurisdictional finding that “BWC was a US person … because it was present in the United States for the bankruptcy proceedings when the transaction occurred.” …