Samuel Cutler October 20, 2015 OFAC Issues Comprehensive JCPOA Guidance Stating That Nothing Has Changed At the heart of the Office of Foreign Assets Control’s (“OFAC”) implementation of the Joint Comprehensive Plan of Action (“JCPOA”)…
Samuel Cutler October 15, 2015 How Canada Enforces U.S. Sanctions and Export Controls While it’s true that Sanction Law focuses primarily on U.S. economic sanctions, on occasion other nations’ enforcement of sanctions and…
Samuel Cutler October 6, 2015 On the (Legal) Irrelevance of Iran Sanctions Act Renewal While the Joint Comprehensive Plan of Action (“JCPOA”) appears to have overcome the last major congressional hurdle to implementation, the…
Samuel Cutler October 5, 2015 Coming Soon to an IEEPA Prosecution Near You: Mandatory Minimums Last week, in a rare moment of bipartisan agreement, a group of nine Democratic and Republican Senators unveiled a sweeping…
Samuel Cutler September 8, 2015 Whither the Liberia Sanctions Program? One of the stranger sanctions regimes maintained by the Office of Foreign Assets Control (“OFAC”) is the Former Liberian Regime…
Samuel Cutler September 3, 2015 How to Really Expedite Your OFAC License Application All this time I believed that the best way to expedite a license request to the Office of Foreign Assets…
Samuel Cutler September 1, 2015 Is There an Enforcement Action in SMBC’s Future? Combing through SEC disclosures mandated by § 219 of the Iran Threat Reduction and Syria Human Rights Act can be…
Samuel Cutler August 31, 2015 Cyber-Related Sanctions Incoming? Since the issuance of Executive Order 13694 on April 1, 2015, the Cyber-Related Sanctions Program has been an empty program,…
Samuel Cutler August 27, 2015 SDGT Removal Highlights EO 13224 Designation Responsibilities Generally speaking, when an email from the U.S. Department of the Treasury referencing a “Counter Terrorism Designation Removal” pops up…
Samuel Cutler August 24, 2015 Don’t Overlook the Civil/Criminal Liability (Potentially) Lurking in the JCPOA’s Foreign Sub Provision As I've written about previously, the license for foreign subsidiaries of U.S. companies described in the Joint Comprehensive Plan of…