On August 24, 2017, OFAC announced a settlement agreement with COSL Singapore Ltd. for apparent violations of the ITSR stemming…
OFAC Settlement Agreement with IPSA Highlights Needs to Reconsider Licensing Policies
On August 10, 2017, OFAC announced a settlement agreement with IPSA International Services, Inc. (IPSA), a U.S. company, for apparent…
Did OFAC Have the Authority to Penalize TransTel?
OFAC's most recent settlement agreement reflects its increasingly broad interpretation of IEEPA’s jurisdictional scope and evidences its willingness to penalize…
ExxonMobil Dealt in Blocked Property, But Is OFAC’s Reasoning Entirely Sound?
It is apparent that ExxonMobil dealt in the services of a blocked person. OFAC could have ended the argument there.…
OFAC Designates Four Iranian Ballistic Missile Entities
On July 28, 2017, OFAC designated four Iranian entities owned or controlled by Shahid Hemmat Industrial Group , an Iranian…
Can Trump Leave the Iran Nuclear Agreement?
The Trump administration reportedly came close to de-certifying Iran's compliance with the JCPOA. If it chooses to do so in…
OFAC, State Announce New Iran Sanctions
In tandem with its certification of Iran’s compliance with the Joint Comprehensive Plan of Action (JCPOA) – the nuclear accord…
Congress Seeks Review Process for Sanctions Easing. Precedent for the Future?
The Senate has taken a big step towards reclaiming Congress' prerogatives over the application of U.S. economic sanctions, including, in…
OFAC Settles Apparent Violations of the CACR
On June 8, 2017, OFAC announced a settlement with the American Honda Finance Corporation for apparent violations of the CACR.…
Epsilon Gives Insight into Scope of Iran Export Ban
The DC Circuit Court of Appeals engaged in an interpretive exercise as to the scope of the Iran export ban…