Samuel Cutler August 13, 2015 Understanding How Sanctions Work: Penalties and U.S. Jurisdiction In the debate surrounding whether Congress should accept or reject a nuclear deal with Iran, there have been a surplus…
Samuel Cutler August 11, 2015 OFAC Reminds Us of the Risks in the JCPOA’s Foreign Subsidiary Provision Last week, the Office of Foreign Assets Control (“OFAC”) provided everyone with an important reminder that the foreign subsidiary license…
Samuel Cutler August 6, 2015 Run, Don’t Walk, to Register for OFAC’s Fall Symposium Less than an hour ago, OFAC sent out an email blast announcing that registration is open for its 2015 Fall…
Samuel Cutler August 6, 2015 Plaintiff’s Lawyers Have Their Own Opinion on the Iran Deal It will be at least a month or so before Congress has its final say on the Iran deal. But…
Samuel Cutler July 31, 2015 You Have the Right to Remain Silent, But It’s Not Always a Good Idea Last week, the Office of Foreign Assets Control (“OFAC”) designated Singapore-based Senat Shipping Limited for providing support to a previously…
Samuel Cutler July 31, 2015 Are the New Ukraine Designations Escalation or Maintenance? Following the recent Ukraine-related designations, media reports can’t seem to decide whether the United States is escalating pressure on Russia…
Samuel Cutler July 31, 2015 Iran’s Phantom PATRIOT Act 311 Designation On July 23, the Financial Crimes Enforcement Network (“FinCEN”) issued a Final Rule pursuant to § 311 of the USA…
Samuel Cutler July 30, 2015 The Greatest Weapon Against the IRGC: American Business? One of the key misconceptions you often encounter about the consequences of sanctions violations is that a monetary penalty can…
Samuel Cutler July 27, 2015 OFAC’s Emphatic Response to those Anticipating an Iran Free-for-All There’s been a great deal of overheated rhetoric about what the nuclear agreement between the P5+1 and Iran means for…
Samuel Cutler July 22, 2015 The Shaky Foundations of an Iran Deal Counter-Argument One of the central critiques of the recently agreed-to Joint Comprehensive Plan of Action (“JCPOA”) is that under the…