<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ofac-jumps-back-in-the-saddle-hits-uae-investment-company-hard/"></div>The U.S. Government shut down gave the folks over at the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) a few weeks of rest and relaxation, but now that they are back they have come out swinging. Today OFAC announced a $1.5 million penalty against a UAE based investment company, Alma Investment, […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on
Category : Erich Ferrari
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/rise-of-the-banks/"></div>While administration of U.S. economic sanctions is legally entrusted to the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), its front line enforcers are U.S. depository institutions. This obviously makes sense as it is these depository institutions who are primarily responsible for catching sanctions violations, blocking and rejecting transactions, and incurring the […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/the-hangover-ofac-targets-mexican-tequila-maker/"></div>Earlier this week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed sanctions on a Mexican tequila company that has allegedly been involved in the laundering of funds on behalf of the Los Gueros organization. The tequila company targeted, El Viejo Luis, was among five companies accused of laundering funds […]<!-- 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/ofac-general-license-d-is-the-d-for-deceiving/"></div>Before any officials of the Office of Foreign Assets Control (“OFAC”) or any other U.S. agency takes this post the wrong way, let me provide a disclaimer: I do not intend to suggest that the U.S. Government has deceived the public as to its good intentions in issuing General License D which allows for the […]<!-- 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/with-two-new-general-licenses-is-ofac-attempting-to-restore-balance-to-the-force/"></div>Today, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the issuance of two (2) general license authorizations in relation to Iran. The first general license, General License E, authorizes the exportation of services and funds transfers by nongovernmental organizations in support of certain not-for-profit humanitarian activities designed to benefit […]<!-- 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/more-ndaa-1245-waivers-issue/"></div>On Friday, the United States announced that it had extended sanctions waivers to ten (10) European Nations and Japan due to their decreasing oil imports from Iran. Of those receiving such waivers, Japan is the only country still importing oil from Iran. As a result of these waivers, foreign financial institutions in those countries will […]<!-- 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/how-should-foreign-financial-institutions-treat-executive-order-13608-designees/"></div>Sometimes forgotten in the long and growing list of Executive Orders directing sanctions to be imposed against various alleged bad actors, is Executive Order (E.O.) 13608 which prohibits certain transactions with, and suspends entry to, the United States of foreign sanctions evaders with respect to Iran and Syria. Just as the name suggests, E.O. 13608 […]<!-- 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/is-the-de-minimis-rule-still-in-the-itsr/"></div>There have recently been a number of sources reporting that there is no longer a de minimus rule contained in the Iranian Transactions and Sanctions Regulations (ITSR). For those of you unfamiliar with the concept of the de minimus rule in the context of Iran sanctions, it is the basic idea that an article created […]<!-- 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/ofac-foia-fiasco-the-story-of/"></div>Let me start off this post by saying that the Freedom of Information Act (FOIA) office at the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has always been responsive, polite, and professional in my dealings with them. Nothing said in this post is meant to slander them. That said, however, disclosures […]<!-- 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/visa-gets-an-ofac-penalty-or-a-notice-or-a-warning-or-something/"></div>Last week the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced an enforcement action against VISA International Services Association (VISA) for violations of 31 CFR Part 501, which constitutes the Reporting, Procedures, and Penalties Regulations governing sanctions programs administered by OFAC. The enforcement action was imposed due to VISA’s failure […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_