New Guidance on OFAC Sanctions Compliance Programs

On May 2, 2019, the Office of Foreign Assets Control (“OFAC”) issued its “Framework for OFAC Compliance Commitments” presenting a number of recommendations for the design, implementation and periodic update of Sanctions Compliance Programs (“SCPs”) by “organizations subject to U.S. jurisdiction and foreign entities that conduct business in or with the United States, U.S. persons, or using U.S.-origin goods or services.”

Is Panama Better Off Now Than When Varela Took Office?

Jaime A. Jácome de la Guardia, Panama-based partner at Diaz, Reus & Targ LLP: “Panama has the second-highest economic growth rate in the region, the highest rate of foreign investment, more efficient public services than average, good transportation infrastructure, communications and energy, a dollarized economy, a sophisticated financial community and a stable liberal democracy…