Roman Abramovich's super yacht Solaris is seen moored at Barcelona Port on March 1, 2022 in Barcelona, Spain. Abramovich has been sanctioned by the U.K. government.
Good question. The U.S. Treasury Department’s Office of Foreign Assets Control administers and enforces sanctions against individuals, companies, and even countries in accordance with U.S. foreign policy goals. These sanctions programs vary in scope, and in the case of Russia include not just specific oligarchs but entities they may own or control. The bottom line is that doing business with a sanctioned party is against the law and punishable by substantial fines and even imprisonment.
That means you would not be legally permitted to, say, purchase a painting for your client from a U.S. gallery at a European art fair, sell a sculpture on his behalf at an American auction house’s Hong Kong branch, or possibly even receive payment from him in U.S. dollars, since dollar wires flow through the U.S. banking system. And because any U.S.
How the heck could I know if a sanctioned party owns 50 percent or more of XYZ Corp? The company definitely won’t put that information on its website. Not a chance. OFAC specifically prohibits people from doing indirectly—such as through an intermediary—what they can’t legally do directly, so this type of workaround would definitely lead to legal problems for you. You need to be careful not even to facilitate a transaction with a sanctioned individual.