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LESSONS FROM OFAC’S FIRST PUBLIC ‘50 PERCENT RULE’

www.hollandhart.com

50 PERCENT RULE’ PENALTY by Jeremy P. Paner, Law360, New York (February 19, 2016, ... at least familiar with the concept of economic sanctions. This understanding of ... As explained by OFAC, between July 2008 and September 2013, Barclays’ New York

  Rules, Understanding, 2013, September, Percent, September 2013, Penalty, Sanctions, 50 percent rule, 50 percent rule penalty

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