Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the issuance of a…
The Evolution of OFAC General Licenses for Legal Services
The United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has discretion to both specifically license particular…
Three Tips for Filing an OFAC License Application to Unblock Funds
Every day, funds transfers are blocked by U.S. financial institutions and others due a belief that the blocking is necessary…
Fulmen Company v. OFAC: It Looks Like Everyone’s Going to Lose
As I have noted over the past year, the United States Department of the Treasury’s Office of Foreign Assets Control…
Shock Gen: The Dangers of the OFAC Voluntary Self-Disclosure
Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement with Société…
They’re Ba-ack….JCPOA Withdrawal Nearing Completion with E.O. 13846
There have been so many questions waiting to be answered since the U.S. announced that they would be withdrawing from…
Is the OFAC SDN List the New Playground for Identity Thieves?
Last month, the United States Court of Appeals for the D.C. Circuit issued an opinion in Chichakli v. Tillerson. For…
IP Services Under The ITSR: A Broad Exception?
If you’ve ever heard me speak at a conference or seminar on U.S. sanctions, then you’ll know one of my…
You Talking to Me? The ITSR, Iranians, and Ordinary Residency
Just because you are a citizen of Iran does not mean that the Iranian Transactions and Sanctions Regulations (“ITSR”) prohibit…