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Did OFAC Have the Authority to Penalize TransTel?

OFAC’s most recent settlement agreement reflects its increasingly broad interpretation of IEEPA’s jurisdictional scope and evidences its willingness to penalize non-U.S. companies for violations of U.S. sanctions regulations.

Are you Dreaming of an OFAC SDN Designation?

I spend a lot of time online. This is due, in part, to the fact that one of my favorite past times is going on Twitter and hearing the endless roar of non-sanctions practitioners (a.k.a. lay persons) scream about who should be on the OFAC SDN List, and complain about...