<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ofacs-new-math-2525-sdn/"></div>In a surprising and unexpected move, OFAC has abruptly changed its six year-old policy regarding what constitutes a blocked person under U.S. sanctions. The revised policy centers on what is referred to as the “50 Percent Rule,” the threshold under which a person is blocked not because they appear on OFAC’s list of Specially Designated Nationals […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter
Category : Guest
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/parsing-sanctions-relief-under-the-joint-plan-of-action/"></div>By now, most if not all of Sanction Law’s regular readers will have at least glanced at the guidance issued by the Office of Foreign Assets Control on the sanctions relief being provided to Iran as part of the implementation of the Joint Plan of Action(JPA). Under the agreement, the P5+1 will suspend certain sanctions […]<!-- 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/mozaffar-khazaee-bumbling-spy-or-disgruntled-employee/"></div>Last week the U.S. Attorney for the District of Connecticut unsealed a criminal complaint against Mozaffar Khazaee, a dual U.S.-Iranian citizen charged with attempting to transport sensitive technical data related to the U.S. Military’s Fifth Generation F-35 Joint Strike Fighter. According to the affidavit filed in support of the complaint, on November 26, Customs and Border […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/iranian-tennis-referee-banned-from-us-open-not-sanctions-fault/"></div>On Wednesday the New York Times ran a story entitled “Sanctions Against Iran Mean a Tennis Referee Can’t Work at the Open.” According to the report, Iranian tennis referee Adel Borghei, a veteran of seven Wimbledon’s and an Australian Open Final, was told in May by the United States Tennis Association that he had been […]<!-- 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/ofac-goes-silent-on-iran/"></div>In the lead-up to Iran’s elections on June 14, 2013, The United States Department of the Treasury’s Office of Foreign Assets Control’s (OFAC) Office of Global Targeting (OGT) went into overdrive, issuing designation after designation. All told, in the month-and-a-half prior to the election OFAC issued six (6) designation actions compromising over 100 individuals, entities, […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_excerpt
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/david-cohens-subtle-but-much-needed-cry-for-help/"></div>During Tuesday’s Senate Banking Committee hearing on Iran sanctions, New Jersey Senator Robert Menendez asked TFI Undersecretary David Cohen a question which has been on our minds for a while now. “We keep adding sanctions regimes, which we need to… Do you have the wherewithal, the resources, to continue to pursue the sanctions regime we […]<!-- 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/poor-advisers-online-travel-agencies-misinterpret-ofac-regulations/"></div>As sanctions have increased over the years, planning a trip to Tehran has gotten progressively more difficult. A brief review of a number of popular online travel booking services bears this out, as each site has a different method of refusing to secure flights to Iran. A search for flights between Washington, D.C.’s Dulles airport […]<!-- 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/mandated-sec-disclosures-for-iran-sanctions-dealings-a-boon-for-law-enforcement/"></div>Don’t look now but combing through SEC filings is about to get a lot more interesting. Under section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRSHRA), all firms which are required to file an annual or quarterly report with the Securities and Exchange Commission (SEC) must include an accounting […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_excerpt
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ofac-designates-m23-leaders-are-ofac-sdn-reconsiderations-all-politics/"></div>Shortly after Thanksgiving I wrote a blog posting calling into question when the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) would designate members of the Congolese rebel group M23. In that posting, I stated that the tools were available under current U.S. economic sanctions programs to designate those parties involved […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/missing-the-forest-for-the-trees-why-iran-sanctions-are-not-flimsy/"></div>There was an op-ed published in the Washington Post last week, which claims that the U.S. has failed to fully deploy economic sanctions to convince Iran to turn away from its pursuit of nuclear weapons and describes the U.S. sanctions regime as “flimsy”. The evidence is a perceived lack of OFAC designations targeting major Iran sanctions violators […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via