<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ofac-issues-faqs-delisting-petitions/"></div>On April 20, 2017, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Frequently Asked Questions (FAQs) regarding petitions for removal from OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List).<!-- 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 --><!--
Category : Blog
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/zte-case-highlights-problem-ofac-enforcement-guidelines/"></div>I like the General Factors Affecting Administrative Action. I really do. If you don’t know what I’m talking about, allow me to provide some background. As you (hopefully) are aware, the United States Department of Treasury’s Office of Foreign Assets Control (OFAC), administers U.S. economic sanctions programs targeting the countries, organizations, persons, etc. that the […]<!-- 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/new-senate-bill-designate-irgc-terrorist-group/"></div>The answer is more complicated than might be expected.<!-- 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 on get_the_excerpt --><!-- AddThis Share Buttons below via filter on get_the_excerpt --><div
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/policy-gap-irgc-sanctions/"></div>Is there a "policy gap" regarding U.S. sanctions targeting the IRGC and its designated agents or affiliates? Proposed legislation seems to think so, yet I am skeptical that this is the 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
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/want-reside-iran/"></div>If a U.S. person is interested in moving to Iran on a permanent basis, can that U.S. person open a bank account there without falling afoul of U.S. sanctions? <!-- 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
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/irgc-sanctions-brief-history/"></div>Reports indicate that the Trump administration is considering the promulgation of an Executive Order that would direct the Secretary of State to designate the Islamic Revolutionary Guard Corps (IRGC) – a branch of Iran’s armed forces – a Foreign Terrorist Organization (FTO) pursuant to Section 219 of the Immigration and Nationality Act (INA). As the […]<!-- 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/is-it-a-new-day-in-iran-sanctions/"></div>Some are characterizing OFAC's latest designations of Iran-related persons as evidence of a new aggressive posture by the Trump administration. But the facts may well tell a different story.<!-- 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 on
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ieepa-so-easy-even-a-caveman-can-understand-it/"></div>Here goes my sour grapes post. There have been a number of motions to dismiss filed by defendants in criminal prosecutions for violations of the International Emergency Economic Powers Act (IEEPA) arising from conduct prohibited by the Iranian Transactions and Sanctions Regulations (ITSR), and its predecessor the Iranian Transactions Regulations. A number of those motions […]<!-- 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/did-rex-tillerson-violate-the-itsr-likely-not/"></div>Rex Tillerson, PEOTUS's nominee to lead the State Department, is expected to face tough questioning during his nominating hearing this morning. Late-inning news reports will place Iran sanctions front-and-center. <!-- 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 on
<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/president-amends-cyber-sanctions-executive-order-sanctions-high-level-russian-government-targets/"></div>On December 29, 2016, President Obama amended Executive Order 13694 – otherwise known as the ‘Cyber Sanctions Executive Order’ – to provide additional authority to the Secretary of the Treasury, acting in concert with the Secretary of State and the Attorney General, to impose blocking sanctions on persons determined to be responsible for or complicit in, or to have engaged in, cyber-enabled activities originating from, or directed by persons located, outside the United States that have the purpose or effect of tampering with, altering, or causing