Compliance with U.S. sanctions regulations has never been easy. As the 2001 Final Report of the Judicial Review Commission on Foreign Assets Control attests, “Members of the legal and business communities who regularly deal with OFAC expressed frustration regarding perceived barriers to effective and efficient compliance with the sanctions programs that OFAC administers.” While some progress has been made, the number of sanctions programs has multiplied in both number and complexity.
Sanction Law was created in December 2008 by Sanction Law Founding Editor Erich Ferrari in order to analyze the legal and policy considerations of this powerful foreign policy tool.
Sanction Law’s mission is to provide a practical, easy to use resource that will assist both expert practitioners and newcomers alike in navigating the world of U.S. economic sanctions.
About the Authors
Mr. Ferrari’s representations before OFAC frequently involve investigations concerning violations of the Iranian Transactions and Sanctions Regulations, the Cuban Assets Control Regulations, and the Counter Narcotics Trafficking Sanctions Regulations. As part of these representations, he has worked to have names removed from OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), and OFAC administrative subpoenas issued during the course of an OFAC investigation, procure OFAC specific licenses to engage in transactions prohibited by OFAC, draft OFAC voluntary self-disclosures, develop and implement OFAC compliance programs for international import-export companies, and provide general counseling on OFAC related matters.
Mr. Cullis has also assisted U.S. parties responding to OFAC administrative subpoenas in the course of federal investigations related to potential sanctions violations and has provided representation to individuals and entities whose names have been identified on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) or BIS-administered lists.