Erich Ferrari Archives - Page 2 of 62 -

They’re Ba-ack….JCPOA Withdrawal Nearing Completion with E.O. 13846

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/theyre-ba-ack-jcpoa-withdrawal-nearing-completion-with-e-o-13846/"></div>There have been so many questions waiting to be answered since the U.S. announced that they would be withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”)–the deal reached between Iran and a number of countries concerning the former’s much disputed nuclear program. For example, who would be put back on the U.S. Department of […]<!-- AddThis Advanced Settings below via

Is the OFAC SDN List the New Playground for Identity

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/is-the-ofac-sdn-list-the-new-playground-for-identity-thieves/"></div>Last month, the United States Court of Appeals for the D.C. Circuit issued an opinion in Chichakli v. Tillerson. For those of you unfamiliar with the litigation, Mr. Chichakli–who was formerly designated pursuant to E.O. 13348 (Liberia)–brought suit against the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. […]<!-- AddThis Advanced Settings below

IP Services Under The ITSR: A Broad Exception?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ip-services-itsr-broad-exception/"></div>If you’ve ever heard me speak at a conference or seminar on U.S. sanctions, then you’ll know one of my favorite sayings is: “when analyzing regulations administered by the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) construe the prohibitions broadly, and the exemptions and authorizations narrowly.” This is almost always […]<!-- AddThis Advanced Settings below via

You Talking to Me? The ITSR, Iranians, and Ordinary Residency

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/talking-itsr-iranians-ordinary-residency/"></div>Just because you are a citizen of Iran does not mean that the Iranian Transactions and Sanctions Regulations (“ITSR”) prohibit U.S. persons from transacting with you. This statement is made in response to one of the most frequently asked questions we receive. These questions usually involve some iteration of facts in which an Iranian national […]<!-- AddThis Advanced Settings below via filter on get_

Crypto-Craze: Will Sanctions Evaders Turn to Cryptocurrencies to Beat OFAC?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/crypto-craze-will-sanctions-evaders-turn-cryptocurrencies-beat-ofac/"></div>If you don’t watch the news, go on the internet, or have friends, then you probably haven’t heard of cryptocurrencies, such as Bitcoin, Ethereum, and Litecoin. While these digital assets have been around for years, they have recently gained increased public attention due to the meteoric rise of their values, particularly over the last several […]<!-- AddThis Advanced Settings below via filter on

Factoring In OFAC’s Enforcement Guidelines

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/factoring-ofacs-enforcement-guidelines/"></div>From what I understand the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), sends out over 1,000 administrative subpoenas every year. Many of these subpoenas go to companies and financial institutions that have the resources to properly respond to OFAC’s inquiries. While such responses are often organized and (sometimes) fully responsive, […]<!-- AddThis Advanced Settings below via filter on get_

Ummm What? Dastranj v. Dehghan

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ummm-dastranj-v-dehghan/"></div>On August 17, 2017, the United States District Court for the District of Maryland issued a memorandum opinion granting in part and denying in part the parties’ cross-motions for summary judgment in the case of Dastranj v. Dehghan, a civil action brought by an Iranian citizen Plaintiff (Dastranj) who brought a series of claims arising […]<!-- AddThis Advanced Settings below via filter on get_the_excerpt --&

New Venezuela Sanctions–Sectoral Sanctions Without the Sectors?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/new-venezuela-sanctions-sectoral-sanctions-without-sectors/"></div>Perhaps lost amidst the weekend’s news of Hurricane Harvey, Seb Gorka resigning, and Joe Arpaio being pardoned, was the announcement of a new Venezuelan sanctions authority, and several associated general licenses. While a new sanctions authority is always news around these parts, what jumped out at me most was the use of prohibitions that looked […]<!-- AddThis Advanced Settings below via filter on get_

Are you Dreaming of an OFAC SDN Designation?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/dreaming-ofac-sdn-designation/"></div>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 why the subject of their […]<!-- AddThis Advanced Settings below via filter on

Not Exactly a Line in the Sand: The D.C. Circuit

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/not-exactly-line-sand-d-c-circuit-attempt-liability-itsr/"></div>Admittedly, I’m late to the party on this, but as you likely already know the D.C. Circuit has issued its decision in the Epsilon Electronics v. U.S. Department of the Treasury litigation that I have spent so much time writing on over the past two years. There is a lot to unpack from that decision–and […]<!-- AddThis Advanced Settings below via

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