• May 2, 2024

The Only Comprehensive Resource on U.S. Economic Sanctions

Category : Blog

Factoring In OFAC’s Enforcement Guidelines

Factoring In OFAC’s Enforcement Guidelines

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/factoring-ofacs-enforcement-guidelines/"></div>From what I understand the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), sends out over 1,000 administrative subpoenas every year. Many of these subpoenas go to companies and financial institutions that have the resources to properly respond to OFAC’s inquiries. While such responses are often organized and (sometimes) fully responsive, […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_

Ummm What? Dastranj v. Dehghan

Ummm What? Dastranj v. Dehghan

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ummm-dastranj-v-dehghan/"></div>On August 17, 2017, the United States District Court for the District of Maryland issued a memorandum opinion granting in part and denying in part the parties’ cross-motions for summary judgment in the case of Dastranj v. Dehghan, a civil action brought by an Iranian citizen Plaintiff (Dastranj) who brought a series of claims arising […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_excerpt --&

New Venezuela Sanctions–Sectoral Sanctions Without the Sectors?

New Venezuela Sanctions–Sectoral Sanctions Without the Sectors?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/new-venezuela-sanctions-sectoral-sanctions-without-sectors/"></div>Perhaps lost amidst the weekend’s news of Hurricane Harvey, Seb Gorka resigning, and Joe Arpaio being pardoned, was the announcement of a new Venezuelan sanctions authority, and several associated general licenses. While a new sanctions authority is always news around these parts, what jumped out at me most was the use of prohibitions that looked […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_

US Sanctions Squeeze China and Russia Over Their Support to

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/us-sanctions-squeeze-china-russia-support-north-korea/"></div>On August 22, 2017, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed a new round of designations targeting certain Chinese and Russian entities and individuals for their North Korean activities.  This unilateral step comes just a couple of weeks after the United Nations Security Council, backed by China and […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_excerpt

Is OFAC’s Application of Its Iran Export Ban Reasonable? The

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ofacs-application-iran-export-ban-reasonable-case-cosl-singapore-ltd/"></div>On August 24, 2017, OFAC announced a settlement agreement with COSL Singapore Ltd. for apparent violations of the ITSR stemming from COSL Singapore’s procurement of U.S.-origin parts for its oil rigs located in the territorial waters of Iran.<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_excerpt --><!-- AddThis Advanced Settings generic via filter on get_the_excerpt -->&

The Impact of the “Countering America’s Adversaries Through Sanctions Act”

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/impact-countering-americas-adversaries-sanctions-act-oil-gas-industry/"></div>The recently enacted “Countering America’s Adversaries Through Sanctions Act” (hereafter “the Act”) bodes rather significant changes for the Oil and Gas Industry. The changes arise from the Russian Sanctions and the Ukrainian crisis.  A review of the initial Executive Order 13662 from September 14, 2014 (Directive 4) versus the provisions of the Act will readily […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_excerpt -->&

OFAC Settlement Agreement with IPSA Highlights Needs to Reconsider Licensing

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ofac-settlement-agreement-ipsa-highlights-needs-reconsider-licensing-policies/"></div>On August 10, 2017, OFAC announced a settlement agreement with IPSA International Services, Inc. (IPSA), a U.S. company, for apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. Part 560.<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_excerpt --><!-- AddThis Advanced Settings generic via filter on get_the_excerpt --><!-- AddThis Share Buttons above via

Did OFAC Have the Authority to Penalize TransTel?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/did-ofac-have-the-authority-to-penalize-transtel/"></div>OFAC's most recent settlement agreement reflects its increasingly broad interpretation of IEEPA’s jurisdictional scope and evidences its willingness to penalize non-U.S. companies for violations of U.S. sanctions regulations.<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_excerpt --><!-- AddThis Advanced Settings generic via filter on get_the_excerpt --><!-- AddThis Share Buttons above via

Are you Dreaming of an OFAC SDN Designation?

Are you Dreaming of an OFAC SDN Designation?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/dreaming-ofac-sdn-designation/"></div>I spend a lot of time online. This is due, in part, to the fact that one of my favorite past times is going on Twitter and hearing the endless roar of non-sanctions practitioners (a.k.a. lay persons) scream about who should be on the OFAC SDN List, and complain about why the subject of their […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on

ExxonMobil Dealt in Blocked Property, But Is OFAC’s Reasoning Entirely

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/exxonmobil-dealt-blocked-property-ofacs-reasoning-entirely-sound/"></div>It is apparent that ExxonMobil dealt in the services of a blocked person. OFAC could have ended the argument there. Instead, it pressed forward a curious argument that undermines its case.<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_excerpt --><!-- AddThis Advanced Settings generic via filter on get_the_excerpt --><!-- AddThis Share Buttons above via filter