My apologies for the title, I just finished watching Creed. Yesterday, the Honorable Reggie B. Walton of the United States…
Paradoxes of the JCPOA Sanctions Relief
It’s only been a few weeks since the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)…
OFAC General License H: The H is for Hold Your Horses
Unless you've been living under a rock since last Friday, you have probably heard that Implementation Day--the day in which…
Shipping to Afghanistan? How is your OFAC Compliance Program Looking?
Over the past year or so, we've seen the United States Department of the Treasury's Office of Foreign Assets Control…
Because OFAC Says So
There is a perception common amongst those practicing in the field of U.S. economic sanctions, that the United States Department…
For Whom OFAC Tolls
As almost all people reading this blog know, the United States Department of the Treasury's Office of Foreign Assets Control…
Fallout From New OFAC SDN Designation May Uncover Details on Syria-ISIS Oil Trade Theory
Last week, the United States Department of the Treasury's Office of Foreign Assets Control ("OFAC") designated four individuals and six…
See You At The Crossroads: OFAC Says Goodbye to an Old Friend
Executive Order 13348 had a good run. But when the United Nations rescinded Security Council Resolution 1521 earlier this year,…
Websites for Marketing of Dietary Supplements to Iran Exempt Under the Information or Informational Materials Exemption
As readers of this blog may know, dietary supplements are generally authorized for export to Iran, pursuant to the general…
Unless You’re the Former Attorney General, Don’t Try This at Home: An Unusual OFAC License is Granted
I came across an interesting opinion from the United States District Court for the District of Columbia the other day…