OFAC Update

On August 2, 2017, President Trump signed a new sanctions bill codifying existing sanctions involving Iran, the Russian Federation, North Korea, and Syria, and adding additional sanctions.  ERISA and governmental benefit plans sometimes overlook that they are also required to comply with such sanctions when investing plan assets and making distributions to participants and beneficiaries. In the attached memorandum, we provide an overview of the U.S. trade sanctions generally, steps that benefit plans can take to comply, and a more detailed look at the recent Russian sanctions in particular.

OFAC Update