Sometimes I forget how much I like being in Court. On Wednesday, Judge Richard Leon, United States District Court Judge…
Deutsche Forfait Is Delisted In An Unusual Way
Yesterday, DF Deutsche Forfait AG (“Deutsche Forfait”), a German trade finance firm, issued a press release regarding their recent delisting…
OFAC Iran SDN Designations Galore
Don’t call it a comeback. On Friday, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)…
Risky Business: No Guidance On Secondary Sanctions Liability
As the number of secondary sanctions authorities at the disposal of the United States Department of the Treasury’s Office of…
A North Korean State Of Mind
We don’t talk too much about North Korea on this blog. Frankly, there isn’t a lot of movement in that…
Tailspin: The Fokker Saga Part II
On June 8, I posted an article related to the Fokker Services (“Fokker”) criminal case pending in the United States…
OFAC Takes A New Approach: Russian Sectoral Sanctions
This past March, President Obama issued Executive Order (E.O.) 13662, targeting those parties dealing in certain sectors of the Russian…
OFAC SDNs, Payments, And The Barter System
One of the great ironies you witness over and over again when you practice in the field of U.S. economic…
OFAC Continues Trend: Publishes Central African Republic Sanctions
July 2014 will go down as the month The United States Department of the Treasury’s Office of Foreign Assets Control…
Burmese Sanctions Regulations Get A Facelift
This past Tuesday, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended and reissued the…