<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/how-to-make-sense-of-the-iranian-bank-account-question/"></div>A big part of addressing any question related to a transaction impacted by a sanctions program administered by the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) is to determine what bank(s) will be involved in the transaction. This is particularly true when dealing with common transactions with Iran. Below I […]<!-- 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-enforcement-in-2011-is-the-big-penalty-era-over/"></div>Although I always hesitate to make predictions, it is my belief that we are in a period of relaxed penalization for violations of U.S. economic sanctions administered by the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”). This does not mean that enforcement is necessarily down, as it does seem from […]<!-- 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/the-cuba-telecommunications-general-license/"></div>Unbeknownst to a large number of U.S. businesses entering into the burgeoning telecommunications space is that it may be very possible to expand their business operations into Cuba. While it is true that there are still sanctions imposed upon Cuba, there is a general license found in the Cuban Assets Control Regulations (“CACR”) administered by […]<!-- 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/kimberly-process-requirements-under-ofac-diamond-sanctions/"></div>Recently we have had a lot of questions on sanctions’ impact on the importation of rough diamonds into the United States. It is fairly common knowledge that all shipments of rough diamonds into the U.S. require a Kimberly Process Certificate and must arrive in a sealed tamper resistance container. However, we have also received some […]<!-- 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-licensing-the-more-the-merrier/"></div>I think something that is lost among many people applying for licenses from the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) to engage in activities that would otherwise be prohibited by U.S. economic sanctions is that OFAC is not alone when determining whether a license should be granted or denied. […]<!-- 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-payment-of-ransoms-to-somali-pirates-violating-ofac-sanctions/"></div>In a case of damned if you do, damned if you don’t, there are news reports floating around about how ransoms being paid by shippers to Somali pirates to free prisoners can expose the shippers to liability for violating economic sanctions administered by the United States Department of the Treasury Office of Foreign Assets Control […]<!-- 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-promulgates-libyan-sanctions-regulations/"></div>Last Friday the United States Department of the Treasury Office of Foreign Assets Control (OFAC) announced the promulgation of the Libyan Sanctions Regulations at 31 C.F.R. Part 570. As was discernible from Executive Order 13566 which imposed these sanctions, the Libyan Sanctions Regulations is a blocking program. Thus, it blocks the assets under U.S. jurisdiction […]<!-- 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-general-license-to-transact-with-sdn-for-next-two-months/"></div>Last Friday, the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) issued a general license which authorized transactions between U.S. persons and Tidewater Middle East Company (“Tidewater”), a newly designated Specially Designated National (SDN) under the Weapons of Mass Destruction Proliferators Sanctions Regulations, for the next two months so long 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/how-will-ofac-address-a-cuban-oil-spill/"></div>Recently questions have been asked regarding whether the restrictions found in the Cuban Assets Control Regulations (“CACR”) will bar U.S. oil spill control technology from reaching Cuba and companies working there if an oil spill accident were to occur off of Cuba. The International Association of Drilling Contractors (“IADC”) in Houston may have the answer. […]<!-- 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/new-iran-sanctions-designations/"></div>Last week the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) and the Department of State designated one individual and two entities under the Iranian Human Rights Sanctions Regulations for inclusion on the List of Specially Designated Nationals (SDN) administered by OFAC. These parties are alleged to be at the core […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_