<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/burma-going-going-but-not-yet-gone/"></div>Last week, President Obama, in light of the expiration of the Burmese Freedom and Democracy Act’s (BFDA) import ban issued an executive order repealing the ban on Burmese imports that was called for by the BFDA and implemented by Executive Order 13310. The new executive order does not lift the ban on Burmese origin jadeite […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_
Category : Erich Ferrari
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/uncle-sam-says-talk-to-the-hand-of-justice-no-lobbying-for-sdns/"></div>This week two individuals from Chicago were arrested for violations of the Zimbabwe sanctions, when they allegedly lobbied on behalf of Zimbabwean President Robert Mugabe without a license from the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC). As the facts have been widely reported, there is no need to reiterate […]<!-- 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-ofac-fed-up-with-frivolous-license-applications/"></div>The heading of this blog posting seems to state a question with an obvious answer: yes, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) obviously doesn’t want to deal with frivolous licenses applications. But the real question is are they fed up with them? The reason I raise this question […]<!-- 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/ofacs-faqs/"></div>I hate knocking the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) for the guidance they publish on their website because quite frankly any guidance we can get from them on the complicated, and sometimes vague, laws they administer is much needed. That said, I shook my head a little bit […]<!-- 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/delegation-of-authority-in-tier-i-kingpin-ofac-delisting-cases/"></div>As I have noted numerous times on this blog not all designations made under the Foreign Narcotics Kingpin Designations Act (“Kingpin Act”) are not the same. There are two tiers of parties designated under the Kingpin Act; namely, Tier I Kingpins and Tier II Kingpins. Tier I Kingpins are those parties identified by the President […]<!-- 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/could-it-be-are-eu-sanctions-culpable-in-failure-of-food-medicine-exports-to-iran/"></div>For over a year now, those in the sanctions policy and legal worlds have been discussing the difficulties that food and medicine exports have had in reaching Iran. A large part of this discussion has focused on U.S. sanctions targeting Iran’s financial sector and how that has impacted the ability of exporters to receive payments […]<!-- 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/do-insurers-get-special-treatment-in-sanctions-matters/"></div>While I hesitate to say that the U.S. Government, or specifically the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), provides special treatment to anyone when it comes to the implementation and administration of U.S. sanctions, it does seem that there are some favorable carve outs or policies for insurers. For […]<!-- 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/a-sanction-for-almost-every-reason-president-obamas-new-executive-order/"></div>I suppose the President has gotten tired of Congress getting all of the attention when it comes to imposing new sanctions on Iran. Earlier this week, the President issued a new executive order implementing certain sanctions that were previously called for in the Iran Freedom and Counter Proliferation Act (IFCA) and adding some new sanctions […]<!-- 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/case-study-brokering-agricultural-commodities-on-behalf-of-a-non-u-s-person/"></div>A few months ago, we wrote a case study on how the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) treated a U.S. company that had sold its majority ownership interest to an Iranian national. In today’s post, we address a newly rendered OFAC enforcement action where they issued a cautionary […]<!-- 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/ofac-designations-and-the-right-to-effective-assistance-of-counsel-a-new-paradigm/"></div>In recent months, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) has engaged in a new trend: the designation of parties to the Specially Designated Nationals and Blocked Persons List (SDN List) who are incarcerated and facing extradition to the United States. The latest example of this came a few […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_