Samuel Cutler July 15, 2015 The Biggest Question Mark for U.S. Businesses in the Iran Deal The long awaited nuclear deal between the P5+1 and Iran, née “The Joint Comprehensive Plan of Action” (“JCPOA”), is upon…
Samuel Cutler July 8, 2015 Senate Fails the Belichick Test, Won’t Confirm Adam Szubin It has been almost three months since President Obama formally nominated Adam Szubin as Undersecretary for Terrorism and Financial Intelligence…
Samuel Cutler July 7, 2015 How I Became a “Volunteer Fed” You may remember a minor uproar several months ago surrounding a newly imposed and quickly retracted policy at the University…
Samuel Cutler July 6, 2015 Those Who Cannot Remember the Past Are Condemned to Repeat It: Iran Edition As the deadline for a comprehensive agreement approaches, many companies are salivating at the prospect of a sanctions-free Iran. With…
Samuel Cutler July 2, 2015 GAO Dives Into the FTO Designation Process Last week the Government Accountability Office (“GAO”) published an interesting report on the Foreign Terrorist Organization (“FTO”) designation process. It’s…
Samuel Cutler June 30, 2015 Is DOJ Overreaching in Texas IEEPA Case? Earlier this week, Taiwanese citizen Kunlin Hsieh pleaded guilty to violations of the International Emergency Economic Powers Act (“IEEPA”) for…
Samuel Cutler June 29, 2015 A Kinder, Gentler, More Responsive OFAC? On June 18, OFAC Acting Director John Smith gave a presentation at a conference organized jointly by Venable LLP and…
Samuel Cutler June 29, 2015 Buzzfeed Doth Protest Too Much, Methinks Last week, Buzzfeed published an expose describing how Reed Business Information (“RBI”), which publishes the widely used Banker’s Almanac,…
Samuel Cutler June 24, 2015 Could the Administration’s New Hostage Policy Leave Banks Vulnerable? In response to criticisms from the families of U.S. citizens who were held hostage by terrorist groups abroad and subsequently…
Samuel Cutler June 22, 2015 Iran-Related SEC Reporting Requirements After a Nuclear Deal: Potential Stumbling Block? There’s still a great deal of uncertainty regarding the scope and timing of sanctions relief under a potential comprehensive nuclear…