Samuel Cutler May 28, 2015 Hastert Proves Structuring Isn’t Just for Drug Dealers While we normally focus exclusively on sanctions here at Sanction Law, it’s important to recognize sanctions and money laundering are…
Samuel Cutler May 28, 2015 Witness the Death of a “Sanctions” Program Almost two months ago we witnessed the birth of a sanctions regime. Yet with sanctions, as in life, birth and death…
Samuel Cutler May 26, 2015 Another EU Designation Appeal Highlights Difficulty in U.S. Challenges Yet another Russian company sanctioned by the European Union has filed an appeal with the European Union Court of Justice…
Samuel Cutler May 26, 2015 Is There Sanctions Liability Lurking in the Dubai Airport? Margaret Ververis, the Senior Associate at Ferrari & Associates, recently returned from trip to Dubai and was nice enough to…
Samuel Cutler May 21, 2015 OFAC/BIS Drop the Hammer on Al-Naser Airlines About a week and a half ago, I flagged Mahan Air’s apparently successful effort to acquire Western commercial aircraft using…
Samuel Cutler May 18, 2015 Iran Walks Back “American Oil Delegation” Claim Last week I wrote a piece on the dangerous new condition known as Iranian Agreement Derangement Syndrome (IADS) in which…
Samuel Cutler May 16, 2015 Potential Risks in Post-deal Iran Investment For companies considering reentry into the Iranian market, there are a number of concerns that should impact the timing and…
Samuel Cutler May 16, 2015 Curious Timing re: Bank of Israel’s Russia Sanctions Letter Israel’s banking regulator has apparently discovered U.S./EU sanctions of Russia according to an Israeli online business portal Globes. Though sanctions…
Samuel Cutler May 15, 2015 OFAC Responds With Motion for Summary Judgment in Epsilon v. Treasury For those of us awaiting new filings in the Epsilon Electronics Inc. v. U.S. Dep’t of Treasury case, the inevitable Motion…
Samuel Cutler May 14, 2015 An Exercise in Redundant Sanctions: HR 2297 Earlier today, the House passed HR 2297 a.k.a. the Hezbollah International Financing Prevention Act, by a vote of 423-0 vote.…