Anyone that knows me can tell you that I get really disappointed by the way courts have handled the definition…
Kingpin Act Reporting Requirements: Quarterly or Annual?
This post is primarily directed to the members of the criminal defense bar that may be representing defendants who have…
Flower Power: Does OFAC’s Recent Enforcement Announcement Highlight Common Misunderstanding?
This week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had settled…
PIJIC Blocked, But Not Identified
As subscribers to the paid portion of SanctionLaw already know, we’ve obtained a lot of information pursuant to Freedom of…
Government Gets Critical Ruling in Iran Sanctions Criminal Case
When the United States Government wants to criminally prosecute someone for a violation of the Iran primary trade embargo–the Iranian…
Better do Your Due Diligence on Doing Due Diligence
Ever since the Joint Plan of Action–the framework to what eventually would become the Joint Comprehensive Plan of Action–was signed…
Three Tips for Responding to OFAC Administrative Subpoenas
It’s been a long time since I’ve written a “how to” piece on SanctionLaw–or anywhere else for that matter. However,…
The Duality of SDN Designations…..You Know the OFAC Thing
If you’re on the United States Department of the Treasury’s Office of Foreign Assets Control’s (OFAC) email subscription list, then…
Oh No, Is OFAC Going After Attorneys???
Last week I was speaking with a friend of mine who serves as inside counsel on sanctions at a major…
OFAC Targets UK Businesses, Businessmen for Support to Mahan Air
Lost in the all of the excitement last week over General License I issued by the United States Department of…