On May 18, 2017, acting pursuant to Executive Order 13692, OFAC designated eight members of Venezuela’s Supreme Court of Justice…
Inaugurating the Terrorist Financing Targeting Center
The United States has entered a historic agreement with its Gulf Arab partners to target terror finance networks. But is…
Have We Entered a New Phase of Iran Sanctions?
Some allege that the Trump administration is taking a more punitive approach towards Tehran.
OFAC Issues FAQs on Delisting Petitions
On April 20, 2017, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Frequently Asked…
Does New Senate Bill Designate IRGC a Terrorist Group?
The answer is more complicated than might be expected.
Is There a “Policy Gap” in IRGC Sanctions?
Is there a "policy gap" regarding U.S. sanctions targeting the IRGC and its designated agents or affiliates? Proposed legislation seems…
So You Want to Reside in Iran?
If a U.S. person is interested in moving to Iran on a permanent basis, can that U.S. person open a…
IRGC Sanctions: A (Brief) History
Reports indicate that the Trump administration is considering the promulgation of an Executive Order that would direct the Secretary of…
Is It a New Day in Iran Sanctions?
Some are characterizing OFAC's latest designations of Iran-related persons as evidence of a new aggressive posture by the Trump administration.…
Did Rex Tillerson Violate the ITSR? Likely Not.
Rex Tillerson, PEOTUS's nominee to lead the State Department, is expected to face tough questioning during his nominating hearing this…