• Introduction of the ​Correspondent Account or Payable-Through Account Sanctions April 17, 2019
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    On March 14, 2019, ​ OFAC announced the replacement of the List of Foreign Financial Institutions Subject to Part 561 (the "Part 561 List") with the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (the “CAPTA List”). The CAPTA List contains identifying information of foreign financial institutions for which the opening or maintaining of a correspondent account or a payable-through account in the United States is prohibited or is subject to one or more strict conditions.

    For more information on how this could impact your business, contact:

    • Martin Lutz, Partner (mlutz@mcginnislaw.com, 512-495-6024)
    • Lindsey Roskopf, Attorney (lroskopf@mcginnislaw.com, 713-615-8534)
    • or another member of the McGinnis Lochridge International Trade and Transactions Practice Group
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