Tyler Cullis August 28, 2017 Is OFAC’s Application of Its Iran Export Ban Reasonable? The Case of COSL Singapore Ltd. On August 24, 2017, OFAC announced a settlement agreement with COSL Singapore Ltd. for apparent violations of the ITSR stemming…
Robert Ward August 24, 2017 The Impact of the “Countering America’s Adversaries Through Sanctions Act” on the Oil and Gas Industry The recently enacted “Countering America’s Adversaries Through Sanctions Act” (hereafter “the Act”) bodes rather significant changes for the Oil and…
Tyler Cullis August 17, 2017 OFAC Settlement Agreement with IPSA Highlights Needs to Reconsider Licensing Policies On August 10, 2017, OFAC announced a settlement agreement with IPSA International Services, Inc. (IPSA), a U.S. company, for apparent…
Tyler Cullis August 11, 2017 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…
Erich Ferrari August 10, 2017 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…
Tyler Cullis August 3, 2017 ExxonMobil Dealt in Blocked Property, But Is OFAC’s Reasoning Entirely Sound? It is apparent that ExxonMobil dealt in the services of a blocked person. OFAC could have ended the argument there.…
Tyler Cullis July 30, 2017 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…
Tyler Cullis July 23, 2017 Can Trump Leave the Iran Nuclear Agreement? The Trump administration reportedly came close to de-certifying Iran's compliance with the JCPOA. If it chooses to do so in…
Tyler Cullis July 19, 2017 OFAC, State Announce New Iran Sanctions In tandem with its certification of Iran’s compliance with the Joint Comprehensive Plan of Action (JCPOA) – the nuclear accord…
Erich Ferrari July 3, 2017 Not Exactly a Line in the Sand: The D.C. Circuit and Attempt Liability Under the ITSR Admittedly, I’m late to the party on this, but as you likely already know the D.C. Circuit has issued its…