Terrific to read Jill Berliner’s guest column, “The Merits of Ditching the Office for an ‘Un-Traditional’ Law Firm,” in Variety.
Proud to call her my partner, colleague and friend.
Not Traditional . . Not Virtual . . Just Evolved
OFAC Targets Sports & Entertainment Figures
– Jill Williamson, Partner, Rimon, P.C.
On August 9, 2017, the Office of Foreign Assets Control (OFAC) at the U.S. Treasury Department, issued a Press Release and identified Mexican national Raul Flores Hernandez and the Flores Drug Trafficking Organization (Flores DTO) as Significant Foreign Narcotics Traffickers pursuant to the Foreign Narcotics Kingpin Designation Act, also known as the Kingpin Act. OFAC also designated a large number of individuals and 42 entities for involvement with, and acting as fronts for, Raul Flores Hernandez.
Many of these individual and entities are in the sports and entertainment industries, including professional soccer player, Rafael Marquez Alvarez (Rafa Marquez), Mexican singer Julio Cesar Alvarez Montelongo (Julion Alvarez), Mexican Soccer Club Club Deportivo Morumbi and the Grand Casino Guadalajara.
As of the issuance date of these designations, no U.S. persons, companies, nor any individuals in the US, are allowed to conduct transactions with these individuals or entities. Penalties under the Kingpin Act can run as high as $10MM per violation, with individual violators subject to imprisonment for up to 30 years. Even civil penalties for inadvertent violations can run over $1M per violation. It is worth noting that OFAC violations are based on strict liability.
If you would like more information, a better understanding or need guidance regarding compliance with these regulations, contact Jill M. Williamson, a Rimon Law Partner based in Washington, DC. Of course you can always contact me, Joe Rosenbaum, or any of the lawyers at Rimon with whom you regularly work.