On August 24, 2017, OFAC announced a settlement agreement with COSL Singapore Ltd. for apparent violations of the ITSR stemming from COSL Singapore’s procurement of U.S.-origin parts for its oil rigs located in the territorial waters of Iran.
The Impact of the “Countering America’s Adversaries Through Sanctions Act” on the Oil and Gas Industry
The recently enacted “Countering America’s Adversaries Through Sanctions Act” (hereafter “the Act”) bodes rather significant changes for the Oil and Gas Industry. The changes arise from the Russian Sanctions and the Ukrainian crisis. A review of the initial Executive...
On August 10, 2017, OFAC announced a settlement agreement with IPSA International Services, Inc. (IPSA), a U.S. company, for apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. Part 560.
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.
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...
It is apparent that ExxonMobil dealt in the services of a blocked person. OFAC could have ended the argument there. Instead, it pressed forward a curious argument that undermines its case.