<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/those-who-cannot-remember-the-past-are-condemned-to-repeat-it-iran-edition/"></div>As the deadline for a comprehensive agreement approaches, many companies are salivating at the prospect of a sanctions-free Iran. With its sizeable middle-class, well-educated population, and developed industrial base, Iran is indeed an attractive market; it would be irresponsible for firms not to be scouting its potential. However, it would be equally foolhardy to let […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_
Category : Guest
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/gao-dives-into-the-fto-designation-process/"></div>Last week the Government Accountability Office (“GAO”) published an interesting report on the Foreign Terrorist Organization (“FTO”) designation process. It’s rare to get a glimpse into the actual process of imposing sanctions so we were pretty excited to see this come out. While the report’s use is somewhat limited given the focus on FTOs, it’s […]<!-- 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/is-doj-overreaching-in-texas-ieepa-case/"></div>Earlier this week, Taiwanese citizen Kunlin Hsieh pleaded guilty to violations of the International Emergency Economic Powers Act (“IEEPA”) for shipping sophisticated electronics parts to Iran without the requisite license from the Office of Foreign Assets Control (“OFAC”). He was arrested in August 2014 along with an alleged co-conspirator, Latvian citizen and Taiwanese resident Agris […]<!-- 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/a-kinder-gentler-more-responsive-ofac/"></div>On June 18, OFAC Acting Director John Smith gave a presentation at a conference organized jointly by Venable LLP and the Stimson Center entitled “The Changing Sanctions Landscape: Past, Present, and Future.” In his speech Smith seemed to go out of his way to address some of the persistent critiques of OFAC that regularly emanate from […]<!-- 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/buzzfeed-doth-protest-too-much-methinks/"></div> Last week, Buzzfeed published an expose describing how Reed Business Information (“RBI”), which publishes the widely used Banker’s Almanac, provided services to an array of unsavory financial institutions in sanctioned jurisdictions. Provocatively titled “As Assad Butchered His People, This London Firm Helped His Banks Trade,” the piece is based on interviews with two anonymous whistleblowers, […]<!-- 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/could-the-administrations-new-hostage-policy-leave-banks-vulnerable/"></div>In response to criticisms from the families of U.S. citizens who were held hostage by terrorist groups abroad and subsequently killed, the administration has announced an overhaul of its hostage policies. One component of this new policy is an explicit rejection of attempts to prosecute individuals for paying ransoms, including to designated Foreign Terrorist Organizations […]<!-- 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/iran-related-sec-reporting-requirements-after-a-nuclear-deal-potential-stumbling-block/"></div>There’s still a great deal of uncertainty regarding the scope and timing of sanctions relief under a potential comprehensive nuclear deal between the P5+1 and Iran. It seems likely that in exchange for verifiable nuclear-related steps on Iran’s part, the U.S. will relax a significant portion of the secondary (i.e. extraterritorial) sanctions currently in place. […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/nbp-compliance-fail-nbd/"></div>Yesterday, in its latest Enforcement Information, the Office of Foreign Assets Control (OFAC) highlighted a recent settlement with the National Bank of Pakistan’s New York Branch. With consideration given to aggravating and mitigating factors, the parties settled for the $28,800 of the total base penalty amount of $64,000. According to OFAC, between June 2013 and […]<!-- 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/are-the-st-louis-cardinals-the-next-sanctions-target/"></div>When we recorded our cyber-sanctions podcast with NYU’s Zach Goldman last week, we laid out a few different scenarios for the initial batch of designations. We generally agreed that at the very least, some Eastern European cyber-criminals or Chinese hackers engaged in corporate espionage would be listed. But it might be time to reconsider in […]<!-- 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/tffc-omits-derisking-from-the-2015-national-money-laundering-risk-assessment/"></div>The 2015 National Money Laundering Risk Assessment (“NMLRA”), produced by Treasury’s Office of Terrorist Financing and Financial Crime (“TFFC”), is an impressive document and an excellent resource on money laundering in the United States. Covering over 90 pages, it analyses every sector of the U.S. financial system and assesses the money-laundering threats, vulnerabilities, consequences, and […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_