The Obama Administration has changed its policy of threatening lawsuit against families of hostages. Sam Cutler discusses how the change in policy could leave banks open to liability.
Added to Sanction Law Premium this week
- GAO: Foreign Terrorist Organization Designation Process and U.S. Agency Enforcement Actions
- The OFAC List: Due Process Challenges in Designation and Delisting
- FOIA: Iran Interpretive Guidances
- Added Practice Tip to 31 C.F.R. § 515.572
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In a recent post, Sam discussed the open question of whether – pursuant to § 5.1.2 of Annex II of the JCPOA –OFAC will provide general or specific license authorization for U.S.-owned or –controlled entities established or maintained outside the United States to engage in otherwise prohibited activities in or with Iran.