The only new wrinkle of concern we have is the severe warning contained in a note we received last month from the US Treasury Department. Treasury is the government agency that is responsible for making sure Americans don't do business with people on a so-called banned list in Zimbabwe. We have told you all along that it was important that you do all you can to verify that your would-be Zimbabwe outfitter is not a banned individual, or a partner of a banned individual. Well, it is even more important than we thought that you do your due diligence, as Treasury has decided to hold US citizens responsible even for unknowing violations of the ban. Here is how Treasury's Molly Millerwise put it in an e-mail last month:
"US persons should do their own due diligence. They should check with OFAC's SDN list (Office of Foreign Assets Control's list of Specially Designated Nationals), which may be accessed at www.treas.gov .ofac. However, even if they unknowingly deal with an SDN or property of an SDN, OFAC may still impose civil penalties of up to $11,000 per violation. If questions remain, US persons should contact OFAC directly.
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