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South Sudan Sanctionable

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/south-sudan-sanctionable/"></div>It has been a while since we have posted, but we’re back by popular demand (actually, just one person’s polite request), and will try to begin posting on Sanctionlaw more often in 2020. We start off these renewed efforts by looking at OFAC’s recent designation of two senior officials of the Government of South Sudan. […]<!-- AddThis Advanced Settings below via filter on

Observe and Report: OFAC Issues Reminder on Annual Blocked Property

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/observe-and-report-ofac-issues-reminder-on-annual-blocked-property-reports/"></div>The United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has been busy over the past few weeks. First, a couple of weeks ago, they issued the amended Reporting, Procedures, and Penalties Regulations, 31 C.F.R. Part 501, which expanded the level of detail required for OFAC blocking and reject reports, and extended […]<!-- AddThis Advanced Settings below via filter on get_

Three Tips for Filing an OFAC License Application to Unblock

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/three-tips-for-filing-an-ofac-license-application-to-unblock-funds/"></div>Every day, funds transfers are blocked by U.S. financial institutions and others due a belief that the blocking is necessary for compliance with U.S. economic sanctions regulations administered by the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). As readers of this blog may be aware, OFAC designates parties alleged to […]<!-- AddThis Advanced Settings below via filter

Fulmen Company v. OFAC: It Looks Like Everyone’s Going to

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/fulmen-company-v-ofac-it-looks-like-everyones-going-to-lose/"></div>As I have noted over the past year, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has increasingly recently found itself defending its actions in U.S. District Court. The latest lawsuit brought against OFAC was lodged by an Iranian entity, Fulmen Company (“Fulmen”), whose request for reconsideration of their designation […]<!-- AddThis Advanced Settings below via filter

Shock Gen: The Dangers of the OFAC Voluntary Self-Disclosure

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/shock-gen-the-dangers-of-the-ofac-voluntary-self-disclosure/"></div>Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement with Société Générale S.A. (“Soc Gen”) for violations of various OFAC administered sanctions programs. The OFAC settlement of $53,966,916.05 represented only a portion of a larger $1.3 billion amount Soc Gen is paying out to various authorities–including, […]<!-- AddThis Advanced Settings below via

They’re Ba-ack….JCPOA Withdrawal Nearing Completion with E.O. 13846

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/theyre-ba-ack-jcpoa-withdrawal-nearing-completion-with-e-o-13846/"></div>There have been so many questions waiting to be answered since the U.S. announced that they would be withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”)–the deal reached between Iran and a number of countries concerning the former’s much disputed nuclear program. For example, who would be put back on the U.S. Department of […]<!-- AddThis Advanced Settings below via

Is the OFAC SDN List the New Playground for Identity

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/is-the-ofac-sdn-list-the-new-playground-for-identity-thieves/"></div>Last month, the United States Court of Appeals for the D.C. Circuit issued an opinion in Chichakli v. Tillerson. For those of you unfamiliar with the litigation, Mr. Chichakli–who was formerly designated pursuant to E.O. 13348 (Liberia)–brought suit against the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. […]<!-- AddThis Advanced Settings below

IP Services Under The ITSR: A Broad Exception?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ip-services-itsr-broad-exception/"></div>If you’ve ever heard me speak at a conference or seminar on U.S. sanctions, then you’ll know one of my favorite sayings is: “when analyzing regulations administered by the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) construe the prohibitions broadly, and the exemptions and authorizations narrowly.” This is almost always […]<!-- AddThis Advanced Settings below via

You Talking to Me? The ITSR, Iranians, and Ordinary Residency

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/talking-itsr-iranians-ordinary-residency/"></div>Just because you are a citizen of Iran does not mean that the Iranian Transactions and Sanctions Regulations (“ITSR”) prohibit U.S. persons from transacting with you. This statement is made in response to one of the most frequently asked questions we receive. These questions usually involve some iteration of facts in which an Iranian national […]<!-- AddThis Advanced Settings below via filter on get_

Crypto-Craze: Will Sanctions Evaders Turn to Cryptocurrencies to Beat OFAC?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/crypto-craze-will-sanctions-evaders-turn-cryptocurrencies-beat-ofac/"></div>If you don’t watch the news, go on the internet, or have friends, then you probably haven’t heard of cryptocurrencies, such as Bitcoin, Ethereum, and Litecoin. While these digital assets have been around for years, they have recently gained increased public attention due to the meteoric rise of their values, particularly over the last several […]<!-- AddThis Advanced Settings below via filter on

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