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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced that 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 of generally authorized activities under the GTSR, including the GTSR general license for legal services. Park Strategies’ executives had actual knowledge of Al-Barakaat’s SDGT status and actively participated in the signing of the contract. OFAC determined that Park Strategies voluntarily disclosed the Apparent Violations, and that the Apparent Violations constitute a non-egregious case.
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