Ferrari Legal, P.C. Archives

Is the De Minimis Rule Still in the ITSR?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/is-the-de-minimis-rule-still-in-the-itsr/"></div>There have recently been a number of sources reporting that there is no longer a de minimus rule contained in the Iranian Transactions and Sanctions Regulations (ITSR). For those of you unfamiliar with the concept of the de minimus rule in the context of Iran sanctions, it is the basic idea that an article created […]<!-- AddThis Advanced Settings below via filter on get_the_

The OFAC FOIA Fiasco: The Story Of Joaquin Mario Valencia-Trujillo

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ofac-foia-fiasco-the-story-of/"></div>Let me start off this post by saying that the Freedom of Information Act (FOIA) office at the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has always been responsive, polite, and professional in my dealings with them. Nothing said in this post is meant to slander them. That said, however, disclosures […]<!-- AddThis Advanced Settings below via filter on

Visa Gets an OFAC Penalty…or a Notice…or a Warning…or Something

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/visa-gets-an-ofac-penalty-or-a-notice-or-a-warning-or-something/"></div>Last week the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced an enforcement action against VISA International Services Association (VISA) for violations of 31 CFR Part 501, which constitutes the Reporting, Procedures, and Penalties Regulations governing sanctions programs administered by OFAC. The enforcement action was imposed due to VISA’s failure […]<!-- AddThis Advanced Settings below via filter on get_the_

Burma…Going….Going…But Not Yet Gone

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/burma-going-going-but-not-yet-gone/"></div>Last week, President Obama, in light of the expiration of the Burmese Freedom and Democracy Act’s (BFDA) import ban issued an executive order repealing the ban on Burmese imports that was called for by the BFDA and implemented by Executive Order 13310. The new executive order does not lift the ban on Burmese origin jadeite […]<!-- AddThis Advanced Settings below via filter on get_the_

Uncle Sam Says Talk to the Hand (of Justice): No

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/uncle-sam-says-talk-to-the-hand-of-justice-no-lobbying-for-sdns/"></div>This week two individuals from Chicago were arrested for violations of the Zimbabwe sanctions, when they allegedly lobbied on behalf of Zimbabwean President Robert Mugabe without a license from the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC). As the facts have been widely reported, there is no need to reiterate […]<!-- AddThis Advanced Settings below via filter on get_

Is OFAC Fed Up With Frivolous License Applications?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/is-ofac-fed-up-with-frivolous-license-applications/"></div>The heading of this blog posting seems to state a question with an obvious answer: yes, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) obviously doesn’t want to deal with frivolous licenses applications. But the real question is are they fed up with them? The reason I raise this question […]<!-- AddThis Advanced Settings below via filter on

OFAC FAQs: The End or Beginning of Your OFAC Inquiry?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ofacs-faqs/"></div>I hate knocking the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) for the guidance they publish on their website because quite frankly any guidance we can get from them on the complicated, and sometimes vague, laws they administer is much needed. That said, I shook my head a little bit […]<!-- AddThis Advanced Settings below via filter on get_

Delegation of Authority In Tier I Kingpin OFAC Delisting Cases

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/delegation-of-authority-in-tier-i-kingpin-ofac-delisting-cases/"></div>As I have noted numerous times on this blog not all designations made under the Foreign Narcotics Kingpin Designations Act (“Kingpin Act”) are not the same. There are two tiers of parties designated under the Kingpin Act; namely, Tier I Kingpins and Tier II Kingpins. Tier I Kingpins are those parties identified by the President […]<!-- AddThis Advanced Settings below via filter on get_the_

Could it Be? Are EU Sanctions Culpable in Failure of

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/could-it-be-are-eu-sanctions-culpable-in-failure-of-food-medicine-exports-to-iran/"></div>For over a year now, those in the sanctions policy and legal worlds have been discussing the difficulties that food and medicine exports have had in reaching Iran. A large part of this discussion has focused on U.S. sanctions targeting Iran’s financial sector and how that has impacted the ability of exporters to receive payments […]<!-- AddThis Advanced Settings below via filter on

Do Insurer’s Get Special Treatment in Sanctions Matters?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/do-insurers-get-special-treatment-in-sanctions-matters/"></div>While I hesitate to say that the U.S. Government, or specifically the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), provides special treatment to anyone when it comes to the implementation and administration of U.S. sanctions, it does seem that there are some favorable carve outs or policies for insurers. For […]<!-- AddThis Advanced Settings below via filter

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