Samuel Cutler August 14, 2014 OFAC’s New Math: 25+25 = SDN In a surprising and unexpected move, OFAC has abruptly changed its six year-old policy regarding what constitutes a blocked person under…
Samuel Cutler January 21, 2014 Parsing Sanctions Relief Under The Joint Plan Of Action By now, most if not all of Sanction Law’s regular readers will have at least glanced at the guidance issued…
Samuel Cutler January 15, 2014 Mozaffar Khazaee: Bumbling Spy Or Disgruntled Employee? Last week the U.S. Attorney for the District of Connecticut unsealed a criminal complaint against Mozaffar Khazaee, a dual U.S.-Iranian…
Samuel Cutler August 24, 2013 Iranian Tennis Referee Banned From US Open; Not Sanctions’ Fault? On Wednesday the New York Times ran a story entitled “Sanctions Against Iran Mean a Tennis Referee Can’t Work at…
Samuel Cutler August 20, 2013 OFAC Goes Silent on Iran In the lead-up to Iran’s elections on June 14, 2013, The United States Department of the Treasury’s Office of Foreign…
Samuel Cutler June 6, 2013 David Cohen’s Subtle, But Much Needed, Cry for Help During Tuesday’s Senate Banking Committee hearing on Iran sanctions, New Jersey Senator Robert Menendez asked TFI Undersecretary David Cohen a…
Samuel Cutler May 9, 2013 Poor Advisers: Online Travel Agencies Misinterpret OFAC Regulations As sanctions have increased over the years, planning a trip to Tehran has gotten progressively more difficult. A brief review…
Samuel Cutler February 23, 2013 Mandated SEC Disclosures for Iran Sanctions Dealings a Boon for Law Enforcement Don’t look now but combing through SEC filings is about to get a lot more interesting. Under section 219 of…
Samuel Cutler December 19, 2012 OFAC Designates M23 Leaders; Are OFAC SDN Reconsiderations All Politics? Shortly after Thanksgiving I wrote a blog posting calling into question when the United States Department of the Treasury’s Office…
Samuel Cutler October 2, 2012 Missing the Forest for the Trees: Why Iran Sanctions are not “Flimsy” There was an op-ed published in the Washington Post last week, which claims that the U.S. has failed to fully deploy economic…