Erich Ferrari December 2, 2018 Shock Gen: The Dangers of the OFAC Voluntary Self-Disclosure Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement with Société…
Erich Ferrari August 23, 2018 They’re Ba-ack….JCPOA Withdrawal Nearing Completion with E.O. 13846 There have been so many questions waiting to be answered since the U.S. announced that they would be withdrawing from…
Erich Ferrari March 21, 2018 Is the OFAC SDN List the New Playground for Identity Thieves? Last month, the United States Court of Appeals for the D.C. Circuit issued an opinion in Chichakli v. Tillerson. For…
Erich Ferrari February 12, 2018 IP Services Under The ITSR: A Broad Exception? If you’ve ever heard me speak at a conference or seminar on U.S. sanctions, then you’ll know one of my…
Erich Ferrari December 22, 2017 You Talking to Me? The ITSR, Iranians, and Ordinary Residency Just because you are a citizen of Iran does not mean that the Iranian Transactions and Sanctions Regulations (“ITSR”) prohibit…
Erich Ferrari December 18, 2017 Crypto-Craze: Will Sanctions Evaders Turn to Cryptocurrencies to Beat OFAC? If you don’t watch the news, go on the internet, or have friends, then you probably haven’t heard of cryptocurrencies,…
Erich Ferrari December 11, 2017 Factoring In OFAC’s Enforcement Guidelines From what I understand the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), sends out over…
Erich Ferrari November 8, 2017 Ummm What? Dastranj v. Dehghan On August 17, 2017, the United States District Court for the District of Maryland issued a memorandum opinion granting in…
Erich Ferrari August 28, 2017 New Venezuela Sanctions–Sectoral Sanctions Without the Sectors? Perhaps lost amidst the weekend’s news of Hurricane Harvey, Seb Gorka resigning, and Joe Arpaio being pardoned, was the announcement…
Robert Ward August 28, 2017 US Sanctions Squeeze China and Russia Over Their Support to North Korea On August 22, 2017, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed a new…