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ENFORCEMENT INFORMATION FOR JANUARY 21, 2020
Park Strategies, LLC Settles Potential Civil Liability for Apparent Violations of the Global Terrorism Sanctions Regulations: Park Strategies, LLC (“Park Strategies”), a lobbying firm located in New York, New York, has paid $12,150 to settle its potential civil liability for Apparent Violations of the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (GTSR). Specifically, from on or about August 25, 2017 to on or about November 25, 2017, Park Strategies appears to have violated § 594.201 of the GTSR when it dealt in the property or interests in property of Al-Barakaat Group of Companies Somalia Limited (“Al-Barakaat”), a Specially Designated Global Terrorist (“SDGT”), when Park Strategies signed a contract with Al-Barakaat and subsequently received payment for its services from Al-Barakaat (the “Apparent Violations”). The contract terms called for Park Strategies to provide lobbying services for Al-Barakaat, which were outside the scope...
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1) THE SCOPE OF THE BOILERPLATE LEGAL SERVICES GENERAL LICENSE
The enforcement action web post outlines the scope of the boilerplate general license for the provision of "legal services" in a manner that generally confirms the reading taken in Case No. SU-3937, especially with regard to lobbying services being outside of the scope of the GL. In this case, OFAC highlighted that “Park Strategies was not a law firm at the time of the Apparent Violations,” but even if it were, OFAC has taken the position that the provision of lobbying or other public relations services by a lawyer is not within the scope of the boilerplate language of the GL for legal services – even when such lobbying services are at least arguably part and parcel of certain forms of legal representation (see again Case No. SU-3937)....