OFAC settles with lobbying firm over contract with Specially Designated Global Terrorist

The US Office of Foreign Assets Control (‘OFAC’) has settled with a New York lobbying firm, Park Strategies LLC, which, it says, undertook services on behalf of a designated company that exceeded the scope of generally authorised activities under the Global Terrorism Sanctions Regulations (‘GTSR’).

In a notice, OFAC said:

‘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.

‘During the time period in which the Apparent Violations occurred, Park Strategies marketed itself as a consulting and government relations firm that provides strategic advisory, consulting, and lobbying services in the areas of federal, state, and local government relations, regulatory affairs, business development, foreign marketplaces, and management and administrative support for trade and industry organizations. Park Strategies was not a law firm at the time of the Apparent Violations.’

In the notice, OFAC described the action as highlighting ‘the important sanctions compliance considerations for attorneys, law firms, and legal services organizations seeking to represent blocked persons as clients.’

It said:

‘Most sanctions programs administered by OFAC have general licenses authorizing the provision of certain enumerated legal services to persons blocked pursuant to those sanctions programs. The provision to blocked persons of legal services not enumerated in such general licenses requires a specific license from OFAC. Other related professional services such as lobbying, public relations, government affairs, consulting, and business development are not legal services, and are generally not covered by general licenses authorizing the provision of legal services to blocked persons.’

See: https://www.treasury.gov/resource-center/sanctions/CivPen/Documents/20200121_park_strategies.pdf