• November 6, 2024

The Only Comprehensive Resource on U.S. Economic Sanctions

Category : Erich Ferrari

Crimea River: OFAC Imposes Sanctions On The Crimea

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/crimea-river-ofac-imposes-sanctions-on-the-crimea/"></div>Lost in all of last week’s news about Cuba sanctions relaxation, and the hustle and bustle preceding the imminent Christmas holiday, was the issuance of a new comprehensive trade embargo targeting the Crimea. Obviously these new sanctions are part of the Ukraine-related sanctions program imposed as a result of the Russian Federation’s actions vis-a-vis the […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on

A Family Affair: OFAC SDN Designations And Familial Relationships

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/a-family-affair-ofac-sdn-designations-and-familial-relationships/"></div>As an attorney who represents parties seeking to be delisted from the United States Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) List of Specially Designated Nationals and Blocked Persons (“SDN List”) one of my most difficult tasks is understanding why a party was designated in the first place. In a majority of […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on

U.S. Persons Assisting Iran’s Tech Startup Community: OFAC Or NOFAC?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/u-s-persons-assisting-irans-tech-startup-community-ofac-or-nofac/"></div>Over the last several months there has been a lot of buzz around Iran’s technology start-up community and their potential for growth and innovation. This has prompted many folks in the U.S. to develop a strong and growing interest on how they can get involved with Iran’s tech start up community. This interest has manifested […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter

OFAC’s Not Always To Blame (Or Credit)

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ofacs-not-always-to-blame-or-credit/"></div>As we enter the final days of the existence of the Joint Plan of Action (“JPOA”)–the interim agreement between the P5+1 and Iran over Iran’s disputed nuclear program–I was reminded of a post I’ve been wanting to write for a while. In a recent license we obtained from that the United States Department of the […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via

Fokker’s Iran Sanctions Violations Prompt The Roar Of The Lion

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/fokkers-iran-sanctions-violations-prompt-the-roar-of-the-lion-of-constitution-avenue/"></div>Sometimes I forget how much I like being in Court. On Wednesday, Judge Richard Leon, United States District Court Judge for the District of Columbia, provided a reminder of why life in the courtroom is so much more interesting than life in the office. As readers of this blog know, I have been following the […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_

Deutsche Forfait Is Delisted In An Unusual Way

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/deutsche-forfait-is-delisted-in-an-unusual-way/"></div>Yesterday, DF Deutsche Forfait AG (“Deutsche Forfait”), a German trade finance firm, issued a press release regarding their recent delisting from the United States Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) List of Specially Designated Nationals and Blocked Persons (“SDN List”). While there is nothing unusual about a company getting off of […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on

OFAC Iran SDN Designations Galore

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ofac-iran-sdn-designations-galore/"></div>Don’t call it a comeback. On Friday, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) unleashed a number of designations targeting Iranian entities under a host of authorities for activities as broad ranging as support for terrorism to evasion of sanctions by acquiring U.S. currency for the Iranian Government. These […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter

Risky Business: No Guidance On Secondary Sanctions Liability

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/risky-business-no-guidance-on-secondary-sanctions-liability/"></div>As the number of secondary sanctions authorities at the disposal of the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) grows, many foreign entities who could become targets of those sanctions have, understandably, had serious concerns about being designated pursuant to one of those authorities. For those of you who don’t […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on

A North Korean State Of Mind

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/a-north-korean-state-of-mind/"></div>We don’t talk too much about North Korea on this blog. Frankly, there isn’t a lot of movement in that program, except for the occasional designations update. That said, this past week was a pretty big one for North Korea sanctions. First, there were some updates to the United States Department of the Treasury’s Office […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter

Tailspin: The Fokker Saga Part II

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/tailspin-the-fokker-saga-part-ii/"></div>On June 8, I posted an article related to the Fokker Services (“Fokker”) criminal case pending in the United States District Court for the District of Columbia. In that article, I detailed the factual basis underlying Fokker’s criminal conduct, and touched upon the fact that Fokker self-disclosed their violations of various U.S. sanctions programs and […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_