<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/determining-a-significant-financial-transaction-under-the-ifsr/"></div>The new sanctions targeting Iran which impose prohibitions on U.S. depository institutions maintaining correspondent or payable through accounts for foreign financial institutions who engage in “significant” transactions with the Central Bank of Iran or other designated banks has caused a number of questions to arise. The most prevalent question is: what constitutes a “significant” transaction […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_
Category : Erich Ferrari
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ofac-issues-more-iran-sdn-designations-for-the-second-day-in-a-row/"></div>For the second day in a row the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated individuals and entities in Iran under one of their sanctions programs. Today, OFAC designated two individuals and four entities pursuant to Executive Order 13382 and the Non-Proliferation of Weapons of Mass Destruction 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/another-iranian-airline-is-designated-for-placement-on-the-ofac-sdn-list/"></div>Today, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated several entities and individuals as Specially Designated Global Terrorists (SDGTs) pursuant to Executive Order (E.O.) 13224. Among those designated were Iranian cargo airline Yas Air, Behineh Trading; three alleged Iranian Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) officials; and one Nigerian […]<!-- 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-amends-the-iranian-transactions-regulations/"></div>Last week the United States Department of the Treasury’s Office of Foreign Assets Control (‘‘OFAC’’) amended the Iranian Financial Sanctions Regulations(‘‘IFSR’’). That amendment caused OFAC to reissue the IFSR in their entirety in order to appropriately implement the mandates of section 1245(d) of the National Defense Authorization Act for Fiscal Year 2012. The IFSR, as […]<!-- 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/more-ofac-information-for-the-insurance-industry/"></div>The previous blog posting we put up on OFAC compliance for the insurance industry received quite a bit of positive attention, so I thought I would expand up on that blog and include some additional information related to sanctions administered by the United States Department of the Treasury’s Office of Assets Control (OFAC) which may […]<!-- 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/usa-v-aviation-services-international-an-examination-of-an-ieepa-violation/"></div>For those of you unfamiliar with the case of USA v. Aviation Services International, B.V. d/b/a Delta Logistics, B.V., (“ASI”) it concerns a U.S.. prosecution of a Dutch aircraft supply company for violations of U.S. economic sanctions, in particular The Iranian Transactions Regulations. In ASI, the defendant (“ASI”) entered a guilty plea to these violations. […]<!-- 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/advertising-for-ofac-licensed-travel-to-cuba/"></div>Ok, so you or your company has obtained a license to facilitate travel arrangements to Cuba for people to people educational exchanges. The next step is letting those licensed parties know about your services. Since both services to be provided and the travel itself are still subject to the authority of the United States Department […]<!-- 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-compliance-for-insurance-providers/"></div>Often times we get questions on how insurance providers should address issues arising from sanctions programs administered by the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). Obviously, the first step is to have interdiction software in place to catch matches to the OFAC Specially Designated Nationals and Blocked Persons (“SDN”) […]<!-- 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/facilitation-under-ofac-administered-sanctions-programs/"></div>One of the least understood and most confusing concepts for those dealing with matter before the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) is that of facilitation. Facilitation is a term used throughout a number of OFAC administered sanctions program which has important consequences for those with indirect involvement in […]<!-- 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/david-levick-indicted-for-criminal-export-violations/"></div>On Wednesday, the United States Attorneys Office for the District of Columbia (USAO) indicted David Levick, an Australian, charging him with violations for the federal conspiracy statute, the International Emergency Economic Powers Act (IEEPA), and the Arms Control Export Act (ACEA), for allegedly exporting U.S. origin goods to Iran. The goods in question were seemingly […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_