Did OFAC Have the Authority to Penalize TransTel?

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.

Are you Dreaming of an OFAC SDN Designation?

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...

OFAC Designates Four Iranian Ballistic Missile Entities

On July 28, 2017, OFAC designated four Iranian entities owned or controlled by Shahid Hemmat Industrial Group , an Iranian entity alleged to be “central to Iran’s ballistic missile program” and designated in the Annex to Executive Order 13382.