Erich Ferrari Archives - Page 3 of 62 -

ZTE Case Highlights Problem with OFAC Enforcement Guidelines

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/zte-case-highlights-problem-ofac-enforcement-guidelines/"></div>I like the General Factors Affecting Administrative Action. I really do. If you don’t know what I’m talking about, allow me to provide some background. As you (hopefully) are aware, the United States Department of Treasury’s Office of Foreign Assets Control (OFAC), administers U.S. economic sanctions programs targeting the countries, organizations, persons, etc. that the […]<!-- AddThis Advanced Settings below via

IEEPA: So Easy Even a Caveman Can Understand It

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ieepa-so-easy-even-a-caveman-can-understand-it/"></div>Here goes my sour grapes post. There have been a number of motions to dismiss filed by defendants in criminal prosecutions for violations of the International Emergency Economic Powers Act (IEEPA) arising from conduct prohibited by the Iranian Transactions and Sanctions Regulations (ITSR), and its predecessor the Iranian Transactions Regulations. A number of those motions […]<!-- AddThis Advanced Settings below via filter on get_the_

Is Epsilon Electronics the Donald J. Trump of OFAC Enforcement

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/is-epsilon-electronics-the-donald-j-trump-of-ofac-enforcement-cases/"></div>I’m going to have to pick up a new hobby once the United States Court of Appeals for the District of Columbia issues its decision in the matter of Epsilon Electronics v. The United States Department of the Treasury’s Office of Foreign Assets Control. For those of you who are new to the blog, have […]<!-- AddThis Advanced Settings below via filter on

Fright Night: OFAC, the Iranian Transactions and Sanctions Regulations, and

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/fright-night-ofac-the-iranian-transactions-sanctions-regulations/"></div>Halloween was yesterday, but there was still something scary on my desk when I walked into the office this morning: the Appellees’ Brief in Epsilon Electronics, Inc. v. United States Department of the Treasury’s Office of Foreign Assets Control (OFAC), an appeal pending before the United States Court of Appeals for the District of Columbia […]<!-- AddThis Advanced Settings below via filter on get_

Seventh Circuit Makes Quick Work of Defendant’s “Willfulness” Jury Instruction

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/seventh-circuit-makes-quick-work-of-defendants-willfulness-jury-instruction-in-us-v-turner/"></div>Anyone that knows me can tell you that I get really disappointed by the way courts have handled the definition of willfulness in criminal prosecutions of violations of the International Emergency Economic Powers Act (IEEPA). For those of unfamiliar with the statute, IEEPA serves as the underlying statutory authority in many sanctions programs. In order […]<!-- AddThis Advanced Settings below via filter on get_the_

Kingpin Act Reporting Requirements: Quarterly or Annual?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/kingpin-act-reporting-requirements-quarterly-or-annual/"></div>This post is primarily directed to the members of the criminal defense bar that may be representing defendants who have been designated by the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) pursuant to the Foreign Narcotics Kingpin Designation Act (“Kingpin Act”). As those lawyers can attest, the provision of many […]<!-- AddThis Advanced Settings below via filter on get_

Flower Power: Does OFAC’s Recent Enforcement Announcement Highlight Common Misunderstanding?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/flower-power-ofacs-recent-enforcement-announcement/"></div>This week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had settled an enforcement case with the PanAmerican Seed Company (“PanAmerican”) to the tune of $4,320,000. The settlement arose out of forty-eight (48) shipments of flower seeds to Iran through intermediaries in third countries. OFAC found that […]<!-- AddThis Advanced Settings below via filter on get_the_excerpt

PIJIC Blocked, But Not Identified

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/pijic-blocked-but-not-identified/"></div>As subscribers to the paid portion of SanctionLaw already know, we’ve obtained a lot of information pursuant to Freedom of Information Act (FOIA) requests submitted to the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) over the years. While a lot of the information we receive is redacted, some of it […]<!-- AddThis Advanced Settings below via filter on

Government Gets Critical Ruling in Iran Sanctions Criminal Case

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/government-gets-critical-ruling-in-iran-sanctions-criminal-case/"></div>When the United States Government wants to criminally prosecute someone for a violation of the Iran primary trade embargo–the Iranian Transactions and Sanctions Regulations (ITSR)–they have a major hurdle to overcome: willfulness. Willfulness is what differentiates a criminal sanctions case from a civil enforcement sanctions case. In the Iran sanctions context this has been defined […]<!-- AddThis Advanced Settings below via filter on

Better do Your Due Diligence on Doing Due Diligence

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/better-do-your-due-diligence-on-doing-due-diligence/"></div>Ever since the Joint Plan of Action–the framework to what eventually would become the Joint Comprehensive Plan of Action–was signed and there was glimmer of sanctions relief for Iran forthcoming, we’ve been getting calls from companies who want to provide “due diligence” services to non-U.S. companies seeking to enter the Iranian market. For non-U.S. service […]<!-- AddThis Advanced Settings below

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