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OFAC Issues Panama General Licenses

The Office of Foreign Assets Control issued general licenses under “Kingpin Act/Panama” on July 21, OFAC said (here). General License 5B is set to expire on Feb. 3, 2017, and authorizes certain transactions necessary during the reorganization of Balboa Bank…

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& Trust by the Superintendency of Banking of Panama and the appointed reorganizer following the superintendency's seizure of Balboa to analyze and make recommendations regarding financial viability and reorganization, or to foster, negotiate or agree to Balboa's reorganization and any subsequent sale, disposition, or transfer of products. This includes software, hardware, goods and services related to bank employment and administration, and building maintenance and operations. General License 6B is set to expire on Feb. 3, 2017, and authorizes all transactions and activities otherwise banned by the Foreign Narcotics Kingpin Designation Act and the Foreign Narcotics Kingpin Sanctions Regulations necessary during the reorganization of Balboa Securities by the Superintendency of the Securities Market of Panama and the appointed reorganizer for inventory of assets and liabilities of Balboa Securities or to foster, negotiate or agree to Balboa Securities' reorganization and any subsequent sale, disposition or transfer of products. That includes exportation, re-exportation, or "provision, directly or indirectly," of software, hardware, goods and services related to bank employment and administration, and building maintenance and operations. Both licenses note that a separate OFAC license will be required for any transaction or activity to finalize, close or exchange assets or "any other thing of value" related to the sale, disposition or transfer of Balboa Bank or Balboa Securities involving a U.S. person or someone otherwise subject to U.S. jurisdiction. OFAC also updated two frequently asked questions about Panama-related activities.