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…
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…
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…
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…
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…
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,…
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…
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…
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…
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…