Erich Ferrari Archives - Page 5 of 62 -

Fallout From New OFAC SDN Designation May Uncover Details on

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/fallout-from-new-ofac-sdn-designation-may-uncover-details-on-syria-isis-oil-trade-theory/"></div>Last week, the United States Department of the Treasury's Office of Foreign Assets Control ("OFAC") designated four individuals and six entities pursuant to Executive Order ("E.O") 13582 alleging that they provided support to the Syrian Government. In the case of one designee, George Haswani, the alleged support...<!

See You At The Crossroads: OFAC Says Goodbye to an

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/see-you-at-the-crossroads-ofac-says-goodbye-to-an-old-friend/"></div>Executive Order 13348 had a good run. But when the United Nations rescinded Security Council Resolution 1521 earlier this year, we knew that time was running out for the United States' sanctions program targeting certain persons related to the former regime of Charles Taylor. <!-- AddThis Advanced Settings generic via filter on get_the_

Websites for Marketing of Dietary Supplements to Iran Exempt Under

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/websites-for-marketing-of-dietary-supplements-to-iran-exempt-under-the-information-or-informational-materials-exemption/"></div>As readers of this blog may know, dietary supplements are generally authorized for export to Iran, pursuant to the general license for export of food found in 31 C.F.R. § 560.530 of the Iranian Transactions and Sanctions Regulations (“ITSR”). A quick scan of the the ITSR shows that...<!-- AddThis Advanced Settings generic

Unless You’re the Former Attorney General, Don’t Try This at

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/unless-youre-the-former-attorney-general-dont-try-this-at-home-an-unusual-ofac-license-is-granted/"></div>I came across an interesting opinion from the United States District Court for the District of Columbia the other day which I hadn’t seen up until this point. The case is Wyatt, et. al. v. Syrian Arab Republic, and it involved a claim against the Government of Syria for its alleged support of the Kuridistan Worker’s Party. <!-- AddThis Advanced Settings below via filter

New Amendments to the Cuban Assets Control Regulations

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/new-amendments-to-the-cuban-assets-control-regulations/"></div>Today, the United States Department of the Treasury announced amendments to the Cuban Assets Controls Regulations (“CACR”) and the Export Administration Regulations (“EAR”) administered by the United States Department of Commerce which expand upon the new policy towards U.S.-Cuba relations.<!-- AddThis Advanced Settings generic via filter on get_the_

The House Gets Desperate on Iran Sanctions Deal

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/the-house-gets-desperate-on-iran-sanctions-deal/"></div>It is rare for me to write anything about the sanctions debate going on in Congress. However, it is unprecedented for me to write back-to-back stories on actions Congress is seeking to take on sanctions. That said, desperate times call for desperate measures, and anti-Iran Deal members of Congress are getting desperate. <!

Head Scratcher of the Week: S.Res.251

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/head-scratcher-of-the-week-s-res-251/"></div>Last Thursday, Rep. Johnson (R-Wis) introduced a Senate resolution concerning the validity of the Joint Comprehensive Plan of Action ("JCPOA"). The resolution states that the congressional review requirement of the Atomic Energy Act of 1954, as added by the Iran Nuclear Agreement Review Act of 2015 (Act), does not apply to the Joint Comprehensive Plan of Action (JCPOA) announced on July 14, 2015, because the President failed to comply with the transmission to Congress requirements. The resolution is essentially predicated on the belief

Ready, Set, Wait: How You Can Predict Receiving an OFAC

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ready-set-wait-how-you-can-predict-receiving-an-ofac-administrative-subpoena-or-grand-jury-subpoena/"></div>One of the most underreported aspects of the recent cases concerning banks being investigated and penalized by regulators–including the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)–for violations of various U.S. economic sanctions programs is the massive amount of information the banks turned over to the U.S. Government during that process.<!-- AddThis Advanced Settings below via

In Defense of the “Inventory Exception”: Epsilon Electronics Goes All

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/in-defense-of-the-inventory-exception-epsilon-electronics-goes-all-in/"></div>Readers of SanctionLaw.com may recall an article that I wrote at the beginning of the year concerning the lawsuit brought by Epsilon Electronics (“Epsilon”) against the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). If you are unfamiliar with this case, it involves a car and audio equipment company that was recently fined by<!-- AddThis Advanced Settings below via

UBS Settlement Highlights the Need for Local Counsel

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ubs-settlement-highlights-the-need-for-local-counsel/"></div>On August 27, 2015, UBS AG (UBS) and OFAC agreed to settle 222 apparent violations of §594.201 of the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594. Per the terms of the settlement agreement, UBS will remit a total of $1,700,100 to settle those apparent violations. The apparent violations are the result of...<!-- AddThis Advanced Settings

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