<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/when-will-the-details-on-sanctions-relief-for-the-interim-deal-be-made-public/"></div>It was announced over the weekend that the technical details of how the Joint Plan of Action (JPA) will be implemented have been worked out and will go into effect on January 20, 2014. For those readers unfamiliar with the JPA it is the document that constitutes the mandates of the interim nuclear deal reached […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_excerpt --&
Category : Erich Ferrari
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/the-future-of-tsra-exports-to-iran/"></div>As we enter 2014 we look back at last year’s developments in the world of U.S. economic sanctions as administered by the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and we see a number of shifts in policy, the law, and in practice. One of the most interesting shifts, and […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ofac-targets-yakuza-affiliates-in-latest-designations/"></div>Shortly before the holidays the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated a number of individuals pursuant to Executive Order (“E.O.”) 13581, the Transnational Criminal Organization Sanctions, for their involvement with the Yamaguchi-gumi Criminal Syndicate, an organization accused of being aligned with the Yakuza. The individuals designated included Tadashi […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/the-fbar-ieepa-one-two-punch-on-accounts-in-iran/"></div>Yesterday, I wrote on what U.S. banks should do in regards to servicing accounts for parties located in Iran. Today, I would like to address the topic of U.S. persons maintaining bank accounts in Iran. First, it should be stated that no U.S. person–defined as U.S. citizens, U.S. permanent legal residents, and those physically present […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/u-s-accounts-opened-andor-held-by-iranians/"></div>We often get questions on what to do with U.S. based accounts which have been opened by Iranians while traveling in the United States or by Iranian Americans who have relocated, either temporarily or permanently, to Iran. Dealing with such accounts can be problematic, however, it is an issue which the United States Department of […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/the-burma-legal-services-general-license-is-not-for-everybody/"></div>I came across an interesting case recently in regards to the general license for legal services under the Burmese Sanctions Regulations, 31 CFR 537.507. That section allows for, among other things, the representation of parties blocked pursuant to 31 CFR 537.201(a) in matters involving representation before any federal or state agency with respect to the […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_excerpt -->&
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ofac-adds-new-terrorism-designations-removes-others/"></div>Today, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the designation of three individuals and one entity pursuant to Executive Order 13224 as Specially Designated Global Terrorists (SDGT). In addition, to these designations OFAC also removed Mohamed Ben Mohamed Abdelhedi from the List of Specially Designated Nationals and Blocked […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/royal-bank-of-scotland-takes-a-hit-and-ofac-tells-all/"></div>Typically when there is a civil penalty announcement by the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) there is not a lot of detail included in the in the announcement. When it does happen it is usually when a financial an enforcement case with a financial institution is being resolved. […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/why-the-chichakli-trial-may-end-today-and-why-the-case-may-not/"></div>As being reported by other sources, the trial of Richard Chichakli, perhaps one of the most famous Specially Designated Nationals (SDNs) in the history of U.S. economic sanctions, will be sent to the jury today for deliberations. Apparently, the defense case–which was already limited by a number of pretrial rulings by the Court–was shortened after […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/representing-sdns-and-how-counsel-of-choice-may-disappear/"></div>I have previously written on the difficulties of representing Specially Designated Nationals and Blocked Persons (“SDNs”) due to issues concerning receipt of funds from blocked sources. As I have mentioned previously, OFAC will only allow for the unblocking of funds to be paid to counsel representing an SDN in an administrative or civil proceeding challenging […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_