Demystifying “Facilitation”: Test Your Knowledge with Practical Scenarios of What Is Permitted

April 25, 2017 5:00pm

Michael Zytnick
Senior Advisor, Group Legal – Global Financial Security
BNP Paribas (New York, NY)

Nicole Sayegh Succar
Senior Vice President, Head of Sanctions Advisory
HSBC North America (New York, NY)

Ashley Coselli
Compliance Attorney
Noble Energy (Houston, TX)

  • Changing nature of the Iran program: now that authorizations for subsidiaries of US persons are permitted, what could a US person still be “facilitating”
  • Aviation, healthcare and other industries: where is the facilitation risk in common industry scenarios?
  • Crimea sectorial sanctions: what can defense, banking and energy players do to ensure they are not engaging in prohibited facilitation of activities with respect to medium and long-term financings?