On August 10, 2017, OFAC announced a settlement agreement with IPSA International Services, Inc. (IPSA), a U.S. company, for apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. Part 560.
OFAC’s most recent settlement agreement reflects its increasingly broad interpretation of IEEPA’s jurisdictional scope and evidences its willingness to penalize non-U.S. companies for violations of U.S. sanctions regulations.
I spend a lot of time online. This is due, in part, to the fact that one of my favorite past times is going on Twitter and hearing the endless roar of non-sanctions practitioners (a.k.a. lay persons) scream about who should be on the OFAC SDN List, and complain about...
It is apparent that ExxonMobil dealt in the services of a blocked person. OFAC could have ended the argument there. Instead, it pressed forward a curious argument that undermines its case.
On July 28, 2017, OFAC designated four Iranian entities owned or controlled by Shahid Hemmat Industrial Group , an Iranian entity alleged to be “central to Iran’s ballistic missile program” and designated in the Annex to Executive Order 13382.